Law Updates

Subject

Summary: The state government of Maharashtra has modified certain clauses of the consent fee system released in August 2026. This modification is being done via Government Resolution No. ENV-2026/CR-158/TC-1, dated 24 September 2026, from the Department of Environment & Climate Change. This Government Resolution has made changes to certain clauses of the older Government Resolution dated 25 August 2026. The changes matter because different types of establishments are now dealt with in different ways. A qualifying Micro or Small enterprise may fall under the deemed Consent to Establish route. A housing or infrastructure project may need to consider sewage-generating slabs. A diesel-generator-only establishment has a separate capacity-based fee table. Healthcare establishments have their own combined consent and Bio-Medical Waste treatment. The same amendment also introduces a single-step procedure for consent under the Water and Air Acts along with applicable authorisations under Waste Management Rules. It further states that 5% of the consent fee is to be credited to the Central Pollution Control Board as a service fee.  For businesses, the first question should therefore be: Which amended clause applies to the establishment? Only after that should the applicable fee or consent route be worked out. Maharashtra MPCB Consent Fee Amendment 2026 at a Glance Particular Details Issuing authority Government of Maharashtra Department Environment and Climate Change Department GR number ENV-2026/CR-158/TC-1 Date 24 September 2026 Earlier GR amended 25 August 2026 Regulatory authority concerned Maharashtra Pollution Control Board Nature of update Amendment to selected consent-fee and consent-procedure provisions Main affected categories Micro and Small enterprises, local bodies, infrastructure projects, DG-only establishments, healthcare establishments and certain BMW-generating entities Effective date Not separately stated in the September GR Main compliance issue Correct identification of category, fee basis and consent route The document is best read as a correction and refinement of the August framework. It substitutes selected clauses and leaves the remaining parts of the earlier GR untouched.  What Exactly Has Maharashtra Changed? The September Resolution replaces six specific parts of the earlier Government Resolution. Clause Subject 2(d) Micro and Small enterprises 3(a) Local Bodies and Infrastructure projects 3(e) Diesel-generator-only establishments 4 Healthcare establishments 5(a) Single-step consent and waste authorisation 5(d) CPCB service fee These six amendments are not identical in nature. Some deal with fee calculation. Some deal with consent procedure. One creates a deemed CTE route for a limited class of Micro and Small enterprises, while another deals with how part of the consent fee is to be credited to CPCB. That is why a business should not read the September GR as a single “new fee chart”. Why Was the August 2026 GR Amended? The September amendment sits within a broader change in the consent framework. The GR records that Section 21A was inserted in the Air Act, 1981 and Section 27A in the Water Act, 1974 through the Jan Vishwas (Amendment of Provisions) Act, 2023. After that, the Ministry of Environment, Forest and Climate Change issued the Control of Air Pollution and Control of Water Pollution (Grant, Refusal or Cancellation of Consent) Guidelines, 2025. Those guidelines were later amended in 2026 and, according to the Maharashtra Resolution, the amended guidelines were in force from 27 January 2026.  Maharashtra enacted its own GR regarding the consent fee on 25 August 2026. Proposal number AS(T)/2026/21 was forwarded by MPCB on 7 September 2026 for some modifications. This was followed up by the state government, and an amendment was enacted by the state government on 24 September 2026.  So the September document should be understood as a follow-up amendment based on MPCB's proposal, not as the starting point of the consent-fee framework. Regulatory Background Behind the Amendment Water (Prevention and Control of Pollution) Act, 1974 Consent under the Water Act is one part of the pollution-control approval structure addressed by the Resolution. The September GR also refers to Section 36 of the Water Act while dealing with the CPCB service-fee provision.  Air (Prevention and Control of Pollution) Act, 1981 Consent under the Air Act is dealt with alongside consent under the Water Act. The preamble refers to Section 21A, while the later CPCB service-fee clause refers to Section 33 of the Air Act.  Environment (Protection) Act, 1986 The Environment (Protection) Act becomes relevant because the amended single-step procedure also covers authorisations under applicable Waste Management Rules notified under that Act.  Maharashtra Pollution Control Board The MPCB is still the major state-level pollution control agency engaged in administering consent. The question is whether the applicant’s project type and environmental situation make him eligible for either of the new fee schemes. Timeline of the 2026 MPCB Consent Fee Changes Date Development Why It Matters 27 January 2026 Amended Central consent guidelines stated to be in force Forms the background framework 25 August 2026 Maharashtra issued the original consent-fee GR Created the earlier state position 7 September 2026 MPCB sent proposal for amendments Led to review of selected clauses 24 September 2026 Maharashtra issued the amendment GR Replaced six specific provisions This timeline shows why there are two Government Resolutions with the same file reference, which appear so close together. It is because the September document amends the previous one rather than creating an entirely new scheme. Old vs New: What Can Be Confirmed? The September GR tells us which clauses have been replaced, but it does not reproduce the complete old wording of every provision. For that reason, an exact old-vs-new comparison should only be made after referring to the official 25 August 2026 GR. What the September document clearly confirms is this: Compliance Area Revised Position Under September GR Micro and Small enterprises Deemed CTE route for qualifying enterprises in duly notified industrial areas on submission of self-certified Form-I Local bodies/infrastructure Revised sewage-based annual fee table DG-only establishments Capacity-based annual fee table Healthcare establishments Combined consent and BMW authorisation treatment Waste authorisation Single-step procedure along with Water/Air Act consent CPCB service fee 5% of consent fee to be credited to CPCB These revised provisions are directly stated in the September GR.   Deemed Consent to Establish for Micro and Small Enterprises Clause 2(d) is particularly relevant for smaller industrial units. The amended clause states that Micro and Small enterprises located in duly notified industrial estates or areas will have Consent to Establish deemed to be granted upon submission of a self-certified Form-I.  That wording contains three important conditions. 1. The enterprise must be Micro or Small The clause does not mention Medium enterprises. 2. The unit must be in a duly notified industrial estate or area MSME status by itself is not enough. 3. A self-certified Form-I must be submitted The deemed CTE treatment is tied to submission of this form. Does This Mean Every MSME Is Exempt from MPCB Consent? No. That is not what the GR says. Eligibility Point Requirement Enterprise type Micro or Small Location Duly notified industrial estate/area Filing requirement Self-certified Form-I Result stated by GR CTE deemed granted The clause creates a deemed Consent to Establish route for a defined category. It does not remove every environmental approval or compliance duty that may apply to an enterprise. A unit may still have to check other environmental permissions, waste authorisations or operational requirements depending on the activity it carries out. For businesses using MPCB consent services , this distinction is important because eligibility should be checked before treating the unit as covered by the deemed route. Revised Consent Fees for Local Bodies and Infrastructure Projects Clause 3(a) deals with Local Bodies and Infrastructure projects. The per-year fee is linked to the quantity of sewage generated. The GR keeps separate rates for: Local Body/Housing; and Other than Housing. Sewage-Based MPCB Fee Slabs Quantum of Sewage Generated Local Body / Housing Other than Housing Up to 10 KLD 5,000 rupees 7,500 rupees Above 10 up to 50 KLD 15,000 rupees 22,500 rupees Above 50 up to 100 KLD 25,000 rupees 37,500 rupees Above 100 up to 300 KLD 35,000 rupees 52,500 rupees Above 300 up to 500 KLD 55,000 rupees 82,500 rupees Above 500 KLD up to 1 MLD 65,000 rupees 97,500 rupees Above 1 up to 5 MLD 75,000 rupees 1,12,500 rupees Above 5 up to 10 MLD 1,00,000 rupees 1,50,000 rupees Above 10 up to 25 MLD 2,00,000 rupees 3,00,000 rupees Above 25 MLD 4,00,000 rupees 6,00,000 rupees These figures come directly from substituted Clause 3(a).  KLD means kilolitres per day. MLD means million litres per day.  The rate therefore depends on both the quantity of sewage and the correct project category. Local Body/Housing and Other-than-Housing Are Not Charged the Same Rate The table itself shows that the two categories are treated separately. For example, a project cannot simply identify that it generates a certain amount of sewage and stop there. It must also know whether the relevant column is: Local Body/Housing; or Other than Housing. That distinction directly changes the annual fee. For developers, infrastructure companies and project consultants, this makes project classification an important part of fee calculation. Consent to Establish Fee for Infrastructure Projects The GR adds another layer for infrastructure projects. It specifically says that Consent to Establish for these projects will be based on the capital-investment formula in Part 2(a).  This means the document uses more than one basis. For annual fee: Sewage generation is relevant. For Consent to Establish: Capital investment is relevant. These two should not be mixed. The September amendment does not reproduce the complete Part 2(a) formula, so the earlier GR remains important where an exact CTE fee calculation is required. An MPCB Consent to Establish consultant reviewing an infrastructure application should therefore check both the project category and the correct fee base, rather than applying only the sewage table. No CTE Rebate for Building and Construction Projects The GR expressly states that there will be no rebate on Consent to Establish for Building and Construction projects falling under Categories 10.0 and 10.1.  This is not a general statement that applies to every type of infrastructure project. It applies to the categories specifically mentioned in the Resolution. Builders and developers falling under these categories should therefore avoid assuming that a CTE rebate available elsewhere in the framework can automatically be used for their project. MPCB Consent Fee for Diesel-Generator-Only Establishments Clause 3(e) provides a separate per-year fee for establishments where a diesel generator is the only source. The words “only source” matter. DG Capacity-Wise Annual Fee DG Rating Annual Fee ≤ 250 KVA Nil 250 KVA to ≤ 500 KVA 1,000 rupees 500 KVA to ≤ 1 MVA 2,000 rupees ≥ 1 MVA 5,000 rupees The rates are taken from the amended clause.  KVA means kilovolt-amperes. MVA means megavolt-amperes. Does This Table Apply to Every Business With a DG Set? The Resolution does not say that. It specifically refers to establishments where the diesel generator is the only source. A factory or commercial unit that has a DG set as backup should therefore not automatically use this table without checking whether the clause actually covers its situation. Similarly, a Nil fee for DG capacity up to 250 KVA should not be treated as proof that no other pollution-control requirement applies. Revised MPCB Rules for Healthcare Establishments Healthcare establishments are dealt with separately in Clause 4. The amended clause is titled: Healthcare Establishments – Combined consent and BMW Authorization. It states that the fee structure for healthcare establishments will be the same as that for industries referred to in Clause 2 of the earlier GR.  BMW means Bio-Medical Waste. For hospitals, clinics and other healthcare establishments, the September amendment therefore needs to be read along with the relevant industry fee structure in the August GR. Combined Consent and BMW Authorisation The wording of Clause 4 brings consent and Bio-Medical Waste authorisation into one combined framework for healthcare establishments. This does not mean BMW obligations disappear. Healthcare establishments still need to determine: whether Bio-Medical Waste rules apply; which consent requirements apply; which fee basis applies; whether they fall under any specific exemption or capital-investment treatment. A Bio-Medical Waste authorisation consultant or environmental compliance professional should therefore examine the establishment's actual category rather than treating all hospitals in the same way. Which Healthcare Establishments Are Exempt from Fees? The September GR gives a clear exemption to certain public healthcare establishments. It states that no fees will be charged to health-service establishments owned and operated by: State Government; Central Government; or Local Body Authorities.  The words owned and operated are important. A healthcare facility should not assume that being connected with a public authority automatically exempts it. The GR does not expressly extend this fee exemption to: private hospitals; charitable hospitals; trust-run hospitals; PPP hospitals; private operators working from public premises. Those cases require separate examination. Medical Colleges, R&D Activities and Industries Generating BMW The amended clause also creates a separate treatment for: Medical Colleges; Research and Development activities; and industries generating Bio-Medical Waste. For these categories, the GR says Consolidated Consent and Authorization will be on a capital-investment basis.  This is different from simply applying the general healthcare establishment rule. A medical college or industrial unit generating BMW should therefore first determine whether this specific proviso applies. Single-Step MPCB Consent and Waste Authorisation Procedure Clause 5(a) introduces a procedural change that is relevant beyond healthcare. The GR states that a single-step procedure will be followed for: consent under the Water Act; consent under the Air Act; and authorisation under applicable Waste Management Rules notified under the Environment (Protection) Act, 1986.  The clause ends with an important qualification: “as per applicability.” Regulatory Area Position Under Amended Clause Water Act consent Included Air Act consent Included Waste Management Rule authorisation Included where applicable Applicability of each waste rule Must still be checked separately What Does “As Per Applicability” Mean? Not every business is governed by every Waste Management Rule. The establishment must first identify which waste stream or environmental rule applies to its operations. The single-step procedure appears to integrate processing. It should not be read as a blanket authorisation covering every environmental law. Does Single-Step Processing Remove Separate Legal Duties? No such removal is stated in the GR. A combined process is not the same thing as removal of substantive obligations. Businesses may still need to comply with applicable requirements relating to: storage; handling; record keeping; disposal; authorised recyclers or treatment facilities; reporting; other conditions under the relevant waste rules. The September GR only states that consent and applicable authorisation are to be dealt with through a single-step procedure. What Does the 5% CPCB Service Fee Provision Mean? Clause 5(d) states that 5% of the consent fee shall be credited to the Central Pollution Control Board as a service fee. The clause refers to Section 36 of the Water Act and Section 33 of the Air Act/the relevant guidelines.  This point needs careful wording. The Resolution says that 5% of the consent fee is to be credited to CPCB. It does not expressly say that an applicant must pay: Consent fee + an additional 5% surcharge. Until such treatment is expressly established from the applicable framework, the safer reading is to describe it as allocation of 5% of the consent fee to CPCB. Who Is Affected by the Maharashtra MPCB Amendment? Stakeholder Clause Main Change Main Check Micro enterprise 2(d) Deemed CTE route Enterprise status, location, Form-I Small enterprise 2(d) Deemed CTE route Enterprise status, location, Form-I Local Body/Housing project 3(a) Sewage-based annual fee Sewage quantity Other infrastructure project 3(a) Separate sewage-based rate Project category Building/construction project 3(a) No CTE rebate for Categories 10.0/10.1 Category DG-only establishment 3(e) DG-rating-based fee Capacity and only-source condition Healthcare establishment 4 Combined consent/BMW treatment Applicable fee structure Government healthcare establishment 4 Fee exemption Ownership and operation Medical College/R&D/BMW industry 4 Capital-investment basis Correct category Other regulated industry 5(a) Single-step process Applicable waste rules How Are MPCB Consent Fees Calculated After the Amendment? There is no one formula for every applicant. The fee basis varies depending on the nature of the establishment. Category Main Basis Local Body/Housing annual fee Sewage generation Other infrastructure annual fee Sewage generation Infrastructure Consent to Establish Capital investment DG-only establishment DG capacity Healthcare establishment Industry fee structure referred to in Clause 2 Medical College/R&D/BMW-generating category Capital investment This is why getting the classification right is more important than simply searching online for an MPCB fee amount. Capital Investment, Sewage Quantity or DG Capacity: Which One Applies? Businesses should first identify the basis attached to their category. Capital Investment Relevant where the GR specifically refers to the capital-investment formula or capital-investment basis. This includes: infrastructure CTE; Medical Colleges; R&D activities; industries generating BMW under the specific proviso. Sewage Quantity Relevant to annual fees for: Local Body/Housing projects; and Other than Housing infrastructure projects. DG Capacity Relevant to establishments where the diesel generator is the only source. Using the wrong basis can result in the wrong fee being calculated even if the arithmetic itself is correct. Impact on Micro and Small Enterprises For the Qualifying MSMEs, the Clause 2(d) could make the process of CTE easier as the GR provides deemed grant after submission of a self-certified Form I. But there is a clear boundary. The unit must be located in a duly notified industrial estate or area. For a Micro or Small enterprise planning to use this route, the practical checks are: confirm enterprise status; verify the status of the industrial estate or area; prepare self-certified Form-I correctly; check whether other environmental permissions apply. An MPCB consent consultant can assist where the unit is unsure whether it falls within the deemed-CTE provision or needs to follow another consent route. Impact on Local Bodies and Housing Projects Local bodies and housing projects now have a clear table of sewage-linked per-year fees. The main work for these applicants is likely to be around: determining sewage generation accurately; identifying the correct slab; confirming whether the project is properly treated under Local Body/Housing; separately calculating CTE where the capital-investment formula applies. For large projects, even a small classification error can place the project in a different fee category. Impact on Builders and Infrastructure Developers Infrastructure projects need to pay attention to two separate concepts. First, the annual fee under Clause 3(a) depends on the amount of sewage generated. Second, Consent to Establish for these projects is tied to the capital-investment formula in Part 2(a). Building and Construction projects falling under Categories 10.0 and 10.1 also do not receive the CTE rebate referred to in the GR. For developers, this means environmental budgeting should not be based solely on sewage quantity. Impact on Healthcare Establishments Healthcare establishments need to identify which part of Clause 4 applies to them. A hospital or healthcare facility may need to check: whether it falls under the general HCE fee framework; whether BMW authorisation is involved; whether it qualifies for the government health-service fee exemption; whether it is a Medical College, R&D activity or BMW-generating industry covered by capital-investment-based consolidated consent. Treating all healthcare establishments as one category can lead to incorrect fee treatment. Impact on Industries Requiring Waste Authorisation For industries requiring waste-related authorisations, Clause 5(a) can affect the way the application is processed. The single-step mechanism may bring together: Water Act consent; Air Act consent; and applicable waste authorisation. But the industry must still know which Waste Management Rule applies to its operations. A business seeking environmental compliance services should therefore ask for an applicability assessment, not merely application filing. Compliance Risks Businesses Should Avoid 1. Assuming MSME Status Alone Is Enough It is not. Clause 2(d) also requires the location to be in a duly notified industrial estate or area and the submission of self-certified Form-I. 2. Application of the Sewage Charge without Considering the Category of the Project For the same sewage amount, the rate will vary based on whether the project comes under Local Body/Housing or Other than Housing category. 3. Use of DG Table for a Standalone Generator The clause is stated for establishments which have the DG as the only generator. 4. Treatment of nil Fee as Nil Compliance Nil charge from any one slab cannot mean nil compliance. 5. Assuming Every Government-Associated Hospital Is Exempt The Resolution says the health-service establishment must be owned and operated by the specified public authority. 6. Ignoring the Capital-Investment Basis Infrastructure CTE and certain medical/R&D/BMW cases use capital investment rather than sewage or DG capacity. 7. Treating Single-Step Approval as a Blanket Environmental Approval Applicable waste rules still have to be identified. 8. Adding 5% to the Applicant's Fee Without Checking The GR says 5% of the consent fee is to be credited to CPCB. It does not expressly call it an extra applicant surcharge. What Existing MPCB Consent Holders Should Review Existing consent holders do not need to assume that every consent must be changed immediately. Instead, they should check whether any of the substituted clauses affect their next filing, renewal, or approval. Useful review points include: current industry or project category; investment amount used for fee purposes; sewage generation; housing/non-housing classification; DG capacity; whether DG is the only source; healthcare/BMW status; public ownership and operation where exemption is claimed; waste authorisations already held; fee calculation for the next consent cycle. What Fresh MPCB Applicants Should Check Before Filing A fresh applicant can reduce classification problems by completing a pre-filing review. Step 1: Identify the Activity Check the actual industrial, healthcare, infrastructure, or service activity. Step 2: Confirm the MPCB Category The appropriate category influences the manner of dealing with consent and fee calculation. Step 3: Micro or Small Enterprise Status Confirmation In the case of Clause 2(d), check enterprise size and its location. Step 4: Confirmation of Fee Base It should be determined that the appropriate basis for the fee is: quantity of sewage; capital cost; DG capacity; or structure of industry related HCE. Step 5: Waste Management Rules' Applicability Check applicability of any Waste Management Rule. Step 6: Reconciliation of Information Prior to Filing The activity, category, fee calculation, and information must match. MPCB Compliance Checklist Check Relevant Entity Why It Matters Micro/Small classification MSMEs Determines Clause 2(d) eligibility Notified industrial area status MSMEs Required for deemed CTE Self-certified Form-I Eligible MSMEs Condition for deemed CTE Sewage quantity Local bodies/infrastructure Determines annual fee slab Housing vs non-housing status Infrastructure Determines correct rate column Capital investment Infrastructure/certain HCE categories Relevant fee basis DG capacity DG-only establishments Determines applicable fee “Only source” condition DG-only establishments Determines whether Clause 3(e) fits Government ownership and operation Healthcare Determines fee exemption BMW applicability Healthcare/medical/R&D/industry Affects consolidated authorisation Waste Rule applicability Industries Determines single-step authorisation scope Business Benefits of the Amendment The September amendment provides more specific treatment for several categories. Clearer MSME Route Eligible Micro and Small enterprises now have a clearly stated deemed CTE provision tied to Form-I and notified industrial areas. Defined Infrastructure Fee Slabs The sewage-based fee table gives local bodies and infrastructure applicants a clearer reference point. Separate DG-Only Fee Structure The amendment provides capacity-based rates instead of leaving the DG-only category unclear. More Specific Healthcare Treatment Healthcare establishments, public healthcare institutions and certain BMW-generating categories are addressed separately. Integrated Consent Procedure Consent under Water and Air laws can be processed, along with applicable waste authorisations, through a single-step procedure. These are procedural and administrative benefits visible from the structure of the amendment. The GR does not promise faster processing, lower compliance costs, or automatic approval. Cost and Administrative Impact on Businesses The cost impact will not be identical across sectors. A housing project may primarily base its annual fee on sewage quantity. An infrastructure project may additionally need the capital-investment formula for Consent to Establish. A DG-only establishment looks at generator rating. A healthcare establishment may need the industry-linked fee structure or the capital-investment route, depending on its category. This makes one point clear: classification comes before calculation. Businesses using MPCB compliance services should therefore ensure that any consultant or internal team first identifies the correct legal and fee category rather than merely applying a standard fee chart. What Businesses Should Do Now Businesses which are affected may consider the following steps: Study the September amendment along with the August 2026 GR. Determine which clause is being substituted. Determine the nature of establishment or project. Determine whether Micro/Small enterprise. Check if notification under industrial area has been made. Check sewage generation under infrastructure projects. Determine capital investment in case GR uses this criteria. Determine DG rating as well as the single source condition. Determine healthcare and BMW applicability. Determine Waste Management Rules authorization. Determine the fee before the next filing. Keep records supporting the chosen classification and calculation. These are practical compliance steps. The September GR does not itself provide a complete application procedure for every category. How Corpseed Can Help with MPCB Consent and Environmental Compliance MPCB applications often become difficult not because of the form itself, but because the business starts with the wrong category, fee basis, or environmental approval requirement. Corpseed can assist businesses with MPCB consent services and related environmental compliance work, including: 1. MPCB Consent to Establish Support Corpseed can help you with applicability checks, classification, documentation, and filing for establishing your business under Consent to Establish. 2. MPCB Consent to Operate Support Businesses moving into the operational stage can obtain assistance with the applicable Consent to Operate requirements and supporting records. 3. Deemed CTE Eligibility Review for MSMEs For Micro and Small enterprises, Corpseed can review whether the unit falls within the notified area and Form-I conditions referred to in the September GR. 4. MPCB Consent Fee Review MPCB consent consultant is able to verify if the appropriate fee basis may be: sewage quantity; capital investment; DG capacity; or some other relevant category as per the consent scheme. 5. Support for Healthcare & BMW Compliance Healthcare facilities are eligible to seek help for: Combined Consent requirements; Bio-Medical Waste authorization and category identification. 6. Rule for Waste Management Applicability Where Clause 5(a) is relevant, Corpseed can help identify which waste authorisations apply to the business before the integrated filing is prepared. 7. Environmental Compliance Gap Review Existing businesses can also review whether their current consent, authorisations and operating conditions match their present activity. 8. Ongoing MPCB Compliance Support Where periodic consent, renewal or related environmental filings are required, Corpseed can assist with document review and ongoing compliance coordination. Businesses unsure about their revised fee category or the correct consent route should consider an applicability review before submitting the application. That can help avoid filing under the wrong category or using the wrong fee basis. Key Takeaways Maharashtra issued Government Resolution No. ENV-2026/CR-158/TC-1 dated 24 September 2026 to amend selected clauses of its 25 August consent-fee GR.  Micro and Small enterprises in duly notified industrial estates/areas can get deemed Consent to Establish on submission of self-certified Form-I, subject to the wording of Clause 2(d).  Local Body/Housing and Other-than-Housing infrastructure projects now have sewage-based annual fee slabs.  Infrastructure CTE remains linked to capital investment, while no CTE rebate is available for Building and Construction Categories 10.0 and 10.1.  DG-only establishments have a separate capacity-based annual fee table.  Healthcare establishments are covered through a combined consent and BMW authorisation framework, with a specific fee exemption for qualifying government health-service establishments.  Water Act consent, Air Act consent and applicable Waste Management Rule authorisations can be dealt with under a single-step procedure.  The GR states that 5% of the consent fee is to be credited to CPCB as a service fee. It does not expressly describe this as an additional 5% surcharge on the applicant. 

Subject

Summary: The Ministry of Labour and Employment has issued Notification S.O. 5206(E) dated 22, September 2026, appointing 1 October, 2026 as the date from which ESI-related contribution, and benefit provisions will apply in the areas identified in the notification. In the English version, the notification covers the entire area of Niwari, which is described as a non-implemented district, along with 24 partially implemented districts in Madhya Pradesh. From 1, October 2026, contributions from employers and employees of establishments in these areas are stated to become payable under Section 29. Employees of such establishments are also to receive benefits under Chapter IV relating to the Employees’ State Insurance Corporation. For employers, the main issue is not a new ESI contribution rate or a new registration form. The real change is geographical implementation. Businesses in areas that were earlier outside full ESI implementation may now need to review their establishment position, employee coverage and payroll setup. There is also one unusual point in the Gazette. The Hindi version refers to districts in Gujarat, while the English version refers to Madhya Pradesh. This difference affects the basic question of where the notification applies, so it should not be ignored. Notification at a Glance Particular Details Issuing authority Ministry of Labour and Employment Notification number S.O. 5206(E) Date of notification 22 September 2026 Date from which provisions apply 1 October 2026 Governing law referred to Code on Social Security, 2020 Relevant Schedule First Schedule Contribution provision Section 29 Benefits provision Chapter IV relating to ESIC State mentioned in English text Madhya Pradesh Non-implemented district Niwari Partially implemented districts 24 Main change ESI implementation across entire areas of listed districts New contribution rate announced? No, not expressly stated New wage ceiling announced? No, not expressly stated Separate grace period Not expressly specified Important source issue Hindi and English texts mention different states This is therefore best read as a coverage and implementation notification, not as a complete rewrite of ESI contribution or registration rules. What Has the Ministry of Labour and Employment Notified? The Central Government has used the power referred to in the third proviso to the First Schedule of the Code on Social Security, 2020 to fix 1 October 2026 as the relevant date for ESI implementation in the specified areas. From that date, the English text states that: contributions from employers are to become payable under Section 29, contributions from employees are also to become payable under Section 29, and benefits under Chapter IV relating to ESIC are to be provided to employees of the concerned establishments. The notification does not introduce a new ESI system. It extends or completes geographical implementation in the areas specifically named in the Gazette. Regulatory Framework Behind the Notification The notification is based on specific provisions of the Code on Social Security, 2020. Understanding these provisions helps explain how the Government has extended the ESI-related coverage to the areas mentioned in the notification. Code on Social Security, 2020 The notification is issued under the Code on Social Security, 2020. For businesses, the practical point is that the Gazette is not operating on its own. It sits within the wider social-security framework and uses the legal mechanism available under the Code to extend ESI-related contribution and benefit provisions to specified geographical areas. First Schedule The Government specifically refers to the third proviso to the First Schedule while issuing S.O. 5206(E).  The notification uses this provision to appoint the date from which the specified areas will move into the notified ESI implementation position. Section 29 Section 29 is the provision mentioned for payment of contributions. The Gazette says that from the appointed date, contributions from employers and employees of establishments situated in the notified areas shall be payable under this section.  The notification itself does not specify a fresh contribution percentage. Chapter IV The notification also refers to Chapter IV in relation to Employees’ State Insurance Corporation benefits. This means the update is not limited to contribution collection. The benefit side of ESI also becomes relevant for employees of establishments falling within the notified coverage. What Changes from 1 October 2026? The simplest way to understand the notification is to look at the earlier geographical status and the position from 1 October 2026. Area Earlier Status Mentioned Position from 1 October 2026 What Businesses Should Review Niwari Non-implemented Position from 1 October 2026 ESI applicability and registration status 24 listed MP districts Partially implemented Entire areas covered Whether business locations were outside earlier covered zones Employer contributions Earlier coverage depended on geographical implementation Payable as notified Payroll and statutory setup Employee contributions Earlier coverage depended on geographical implementation Payable as notified Employee mapping and payroll deductions ESIC benefits Earlier implementation differed by area Benefits under Chapter IV become relevant Employee coverage records The important phrase here is “entire area.” In a partially implemented district, some places may have been covered earlier while others were not. From 1 October 2026, the notification extends implementation across the full district area mentioned in the English version. ESI Coverage Expansion from 1 October 2026 The ESI coverage expansion 2026 is mainly about completing geographical implementation in the districts named in the notification. For many employers, that may mean their earlier position needs to be checked again. A company may have operated in a district where ESI was already partly implemented, but its own factory, warehouse or branch may have been outside the earlier covered area. Once the entire district is brought under implementation, that old assumption may no longer remain valid. This is why employers should focus first on their actual establishment location, rather than only asking whether the company already has an ESIC number somewhere else. Scope and Applicability: What Businesses Need to Understand There are two separate questions. 1. Is ESI implemented in the geographical area? This notification deals directly with that issue. The English version brings the entire area of Niwari and the 24 listed partially implemented districts within the notified implementation from 1 October 2026. 2. Does ESI apply to the specific establishment? That is a separate assessment. Simply being located in a notified district does not automatically answer every question about ESI coverage. A business may still need to check: the type of establishment, applicable legal conditions, its existing ESIC status, employee coverage, branch or unit location, other requirements under the governing law. This distinction is important because geographical implementation and establishment-level applicability are related, but they are not identical. Districts Covered Under the English Version of S.O. 5206(E) The English text identifies Madhya Pradesh and divides the covered areas into one non-implemented district and 24 partially implemented districts. Niwari- Non-Implemented District Niwari is the only district described in the English notification as non-implemented. From 1 October 2026, the notification applies to the entire area of Niwari.  For employers operating there, this means an earlier decision based on the district being outside full ESI implementation should now be reviewed. 24 Partially Implemented Districts The English version lists the following 24 districts:  S. No. District Earlier Status Mentioned From 1 October 2026 1 Agar Malwa Partially implemented Entire area covered 2 Alirajpur Partially implemented Entire area covered 3 Anuppur Partially implemented Entire area covered 4 Ashoknagar Partially implemented Entire area covered 5 Balaghat Partially implemented Entire area covered 6 Barwani Partially implemented Entire area covered 7 Betul Partially implemented Entire area covered 8 Chhatarpur Partially implemented Entire area covered 9 Damoh Partially implemented Entire area covered 10 Datia Partially implemented Entire area covered 11 Harda Partially implemented Entire area covered 12 Jhabua Partially implemented Entire area covered 13 Mandla Partially implemented Entire area covered 14 Narsinghpur Partially implemented Entire area covered 15 Panna Partially implemented Entire area covered 16 Rajgarh Partially implemented Entire area covered 17 Seoni Partially implemented Entire area covered 18 Sheopur Partially implemented Entire area covered 19 Shivpuri Partially implemented Entire area covered 20 Sidhi Partially implemented Entire area covered 21 Tikamgarh Partially implemented Entire area covered 22 Umaria Partially implemented Entire area covered 23 Vidisha Partially implemented Entire area covered 24 Dindori Partially implemented Entire area covered For an employer with a factory or branch in any of these districts, the next step is not to assume immediate liability blindly. The right approach is to check whether the establishment itself falls within the legal ESI framework. What Do “Non-Implemented” and “Partially Implemented” Mean? The Gazette does not provide a detailed definition of these expressions. In the context of this notification: Non-implemented refers to a district where the relevant ESI implementation had not previously extended in the manner now notified. Partially implemented refers to a district where only part of the geographical area had earlier been brought under implementation. The new notification uses the wording “entire areas”, which indicates completion of geographical coverage across the listed districts.  That is particularly relevant for businesses located in places that were outside earlier notified zones. Why “Entire Area” Matters for Employers The words “entire area” may look routine, but they are one of the most commercially relevant parts of the notification. Consider what this means for business operations. A company may have: a factory in one part of a district, a warehouse outside the main urban area, a branch in an industrial cluster, a depot in a rural location, an office in a town that was outside the earlier implementation zone. If only part of the district was previously covered, the company may have followed a different compliance position for that location. From 1 October 2026, that location may need a fresh ESI applicability review. This is where an ESIC applicability assessment becomes useful, especially for businesses with several units or branches. When Will Employer and Employee Contributions Become Payable? The notification fixes 1 October 2026 as the relevant date. From that date, contributions from employers and employees of establishments falling within the notified coverage are stated to be payable under Section 29.  Businesses should therefore not wait until a later payroll cycle to start examining applicability. The review should ideally cover: establishment coverage, employee mapping, ESIC registration status, payroll settings, statutory deduction configuration. The notification does not itself state a revised contribution percentage. Employer-Side Impact For employers in the newly covered areas, the change may first affect payroll and registration records. Areas Employers Should Review: Establishment Registration Status: Check whether the unit is correctly reflected in ESIC records. Branch and Location Mapping: Businesses with multiple branches should check each location separately rather than assuming that registration at one location covers all establishments. Employee Mapping: Check that employees are linked to the correct establishment or branch. Payroll Setup: Payroll teams should check whether the ESI settings are correctly applied to employees covered by the new notification. Businesses that are unsure of their position may use ESIC registration services or an ESIC registration consultant to check applicability before making changes. For employers in the newly covered areas, the practical impact may be felt first in payroll and registration records. Employee-Side Impact Employees working in newly covered establishments may also see changes. Depending on the applicable legal conditions, the change may affect: employee contribution treatment, payroll deductions, ESIC employee records, establishment linkage, access to relevant ESIC benefits. The Gazette does not say that every employee in every listed district automatically becomes covered. The employer should first establish whether the establishment and employee fall within the applicable legal framework. What ESI Benefits Become Relevant? The notification states that benefits under Chapter IV relating to the Employees’ State Insurance Corporation will be provided to employees of the establishments covered by the notification.  The two-page Gazette does not separately list every benefit. For that reason, businesses should not present a long list of benefits as though each one was newly created by S.O. 5206(E). The notification is better understood as making the existing benefit framework relevant in the newly implemented geographical areas. Does Every Business in These Districts Automatically Come Under ESI? Not necessarily. The district list tells a business where ESI implementation has been extended. It does not, by itself, settle every establishment-level question. An employer should still review: nature of establishment, applicable legal conditions, employee profile, existing registration status, location of individual branches or units, other applicable ESI provisions. This is why a proper ESIC applicability assessment should come before registration or payroll changes. Existing Position vs Position from 1 October 2026 Issue Earlier Position Mentioned From 1 October 2026 Niwari Non-implemented Entire area brought under implementation 24 MP districts Partially implemented Entire areas brought under implementation Employer contribution Depended on earlier geographical implementation Payable as specified Employee contribution Depended on earlier geographical implementation Payable as specified ESIC benefits Geographic coverage was not complete Benefits become relevant as notified The Gazette does not provide a detailed historical timeline for each district, so those dates should not be invented. Implementation Timeline Event Date What It Means Notification issued 22 September 2026 Government formally issued S.O. 5206(E) Provisions take effect in specified areas 1 October 2026 Contributions and benefits apply as notified There is only a short gap between the notification date and the implementation date. That does not mean the Government has provided a formal grace period. No such separate grace period is expressly mentioned. Impact on Different Types of Employers The impact of the notification may differ depending on where an establishment operates, and whether its area was already covered under ESI. Employers should review their locations separately rather than treating the change as a company-wide update. Employers in Niwari Employers in Niwari should review whether their earlier compliance position was based on the district being non-implemented. From 1, October 2026, that basis may no longer remain available. Employers in the 24 Partially Implemented Districts The most important question for these employers is location. A business may already be in a district where some areas were covered, but its particular unit may previously have been outside that coverage. The move to the entire district area changes that geographical position. Multi-Location Businesses Businesses operating from multiple locations should carry out the review branch by branch. For example, internal records should identify separately: registered office, factory, warehouse, branch, depot, shop, operational unit. A blanket company-wide assumption can create errors where different units have different regulatory histories. Payroll and HR Changes Businesses Should Review The notification does not set out a new payroll procedure. Still, employers in the affected areas should check their payroll and HR records before the implementation date. HR and payroll teams should look at: Payroll Master: Check the ESI details in the payroll system for employees working at the affected establishments. Employee Work Location: Make sure the location attached to the employee record matches the actual establishment. Establishment Code: Check that the correct ESIC establishment details are being used. Contribution Settings: Check whether the payroll settings need to change from 1, October 2026. Employee Records: Check that joining details, branch mapping and statutory records match. Internal Compliance Calendar: Add the 1 October 2026 change to the compliance calendar so that payroll, HR and finance teams are working from the same date. These are practical internal controls, not additional obligations expressly listed in S.O. 5206(E). What Employers Should Check Before 1 October 2026 A sensible review can be carried out in the following order. 1. Check the Establishment Address Use the actual operational address, not only the company’s registered office. 2. Identify the District Confirm whether the unit falls in one of the listed areas. 3. Review Earlier Implementation Status Find out whether the establishment was in a previously implemented or non-implemented part of the district. 4. Check ESI Applicability Review whether the establishment itself falls within the applicable legal framework. 5. Review ESIC Registration If registration already exists, check whether branch, and establishment details are correct. 6. Check Employee Coverage Identify employees who may be affected. 7. Review Payroll Check statutory deductions and employer contribution configuration. 8. Check the Gazette Discrepancy Do not ignore the Gujarat–Madhya Pradesh difference. 9. Monitor Official Clarification Look for a corrigendum or clarification from the Government or ESIC. 10. Keep an Internal Record Document how the compliance position was decided. Does the Notification Change ESI Contribution Rates? No new contribution percentage is expressly given in S.O. 5206(E). The notification is concerned with: geographical implementation, commencement of contribution liability, availability of relevant ESIC benefits. A business should therefore not describe this as an ESI contribution-rate revision. Does the Notification Change the ESI Wage Ceiling? The Gazette does not expressly prescribe or revise an ESI wage ceiling. If a business needs to determine employee-level coverage, that question should be checked separately under the applicable ESI legal framework. Is Any Grace Period Available? No separate grace period or transition period is expressly stated. The notification fixes 1 October 2026 as the date from which the relevant provisions apply.  Employers should therefore avoid assuming that a later adjustment period is automatically available. What S.O. 5206(E) Does Not Tell Businesses The notification is short. It does not attempt to cover the whole ESI compliance process. It does not expressly specify: new contribution percentages, wage ceiling, registration form, registration procedure, document checklist, portal filing process, return format, payment workflow, inspection procedure, new penalty amount, separate grace period, exemption process. Where these issues matter, they should be checked separately under the applicable legal, and ESIC framework. Important Gazette Discrepancy: Gujarat vs Madhya Pradesh This part deserves special attention. The Hindi portion of the Gazette refers to Gujarat and mentions 15 non-implemented districts and 16 partially implemented districts.  The English portion refers to Madhya Pradesh and lists one non-implemented district and 24 partially implemented districts.  Version State Mentioned Geographic Coverage Mentioned Hindi Gujarat 15 non-implemented + 16 partially implemented districts English Madhya Pradesh 1 non-implemented + 24 partially implemented districts This is not a small spelling difference. It changes the state and the entire district list. For an employer, that can change whether the notification applies at all. The attached Gazette does not explain why the two versions differ. It would therefore be unsafe to call one version correct and the other a printing mistake without further official clarification. What Should Businesses Do About the Gujarat-Madhya Pradesh Difference? Businesses potentially affected by this notification should check the position before relying on one language version alone. A practical approach is to: check whether a corrigendum has been issued, review subsequent Ministry of Labour and Employment notifications, check ESIC communications, confirm the establishment’s exact location, keep a record of the official source used, obtain professional advice where the compliance outcome depends on the state reference. This is especially relevant where payroll changes or registration decisions have to be made immediately. Business Impact Matrix Stakeholder Likely Impact Immediate Review Area Employers ESI applicability may change Establishment coverage HR teams Employee mapping may need revision Employee records Payroll teams Contribution treatment may need updating Payroll configuration Compliance teams Geographic interpretation required Gazette and clarification Multi-location businesses Different units may be affected differently Branch mapping Employees Contribution and benefit implications ESIC coverage Common Compliance Risks to Avoid Employers should avoid a few easy assumptions. Assuming every business in a notified district is automatically covered: The district list sets the geographical area, but other conditions may still apply to the establishment. Assuming every employee is automatically covered: Employee-level applicability still needs to be checked. Using old district implementation information: An earlier compliance review may not reflect the position from 1 October, 2026. Ignoring smaller branches or warehouses: A branch, warehouse, or other unit can also matter when checking geographical applicability. Treating the Gazette as a rate amendment: The notification does not expressly change the contribution percentage. Assuming a grace period: The notification does not expressly provide a separate grace period. Ignoring the language discrepancy: The Gujarat-Madhya Pradesh difference should be checked and verified. What Businesses Should Do Next For businesses operating in any potentially affected area, the next steps should be practical rather than rushed. Prepare a list of all establishments and branches. Confirm their exact district and location. Check whether the location appears in the relevant Gazette text. Review establishment-level ESI applicability. Check existing ESIC registration. Review employee coverage. Review payroll and statutory deduction settings. Check for official clarification on the language discrepancy. Update internal compliance records where required. Keep monitoring ESIC and Ministry updates. How Corpseed Can Help with ESIC Registration and Compliance An ESI expansion notification can create uncertainty for businesses that were earlier outside full geographical implementation. The first question is often not “How do we register?” but “Does this establishment now come under ESI?” Corpseed can support businesses with: 1. ESIC Applicability Assessment Review the establishment location, business structure and existing ESI position before any registration or payroll change is made. 2. ESIC Registration Services Corpseed provides ESIC registration services for businesses that are required to complete or update their registration under the applicable framework. 3. Branch and Establishment Review For companies with more than one location, Corpseed can help review branch-wise applicability rather than relying on one company-wide assumption. 4. Employee Coverage Review Employee records can be checked against the applicable ESI framework to identify where compliance action may be needed. 5. Payroll Compliance Support Payroll teams can receive support in reviewing ESI-related statutory treatment after applicability has been confirmed. 6. ESIC Registration Consultant Support Businesses that are unsure about their registration status, establishment details or location coverage can consult an ESIC registration consultant before making any changes. 7. Labour Law Compliance Services Where the ESI review forms part of a wider HR or labour-law exercise, Corpseed can also assist with related labour law compliance services. 8. Ongoing ESI Compliance Services Businesses may also need help after registration with ongoing records, filings and establishment-level compliance support, depending on the applicable requirements. For businesses operating in newly implemented areas, the better approach is to first confirm applicability and then proceed with ESIC registration services or payroll changes only where required. Key Takeaways S.O. 5206(E) was issued by the Ministry of Labour and Employment on 22, September 2026. The relevant implementation date is 1 October, 2026. The English version covers Niwari and 24 partially implemented districts in Madhya Pradesh.  The notification refers to employer and employee contributions under Section 29. It also refers to ESIC benefits under Chapter IV. The notification does not expressly revise contribution rates or the wage ceiling. No separate transition or grace period is stated. Employers should pay particular attention to the phrase “entire area” in relation to previously partially implemented districts. The Hindi text refers to Gujarat while the English text refers to Madhya Pradesh, and this geographical inconsistency should be checked against any official corrigendum or clarification.

Subject

Summary: A two-page Gazette can sometimes create more questions than a fifty-page rulebook. S.O. 5176(E) is one such notification. The Ministry of Communications, Department of Telecommunications, through the Telecommunication Engineering Centre ( TEC ), has notified TSDSI-transposed 3GPP Standards covering Releases 15 to 18 for adoption as National Standards for telecommunication equipment. The batch is linked to TSG#109 and contains 202 documents. The notification itself is dated 17 September 2026.  For a telecom manufacturer or importer, the immediate concern may be: does this mean 202 fresh compliance requirements now apply to every product? The notification should not be read that way. It adopts a set of standards into India's national telecom standards framework. Whether one of those standards translates into a mandatory testing, conformity-assessment, or certification requirement for a particular product still requires a product-specific regulatory check. That distinction is where most of the practical work lies. Notification at a Glance Particular Verified Position Ministry Ministry of Communications Department Department of Telecommunications Authority Telecommunication Engineering Centre Notification Number S.O. 5176(E) File Number 24-04/2026-STD/TEC Notification Date 17 September 2026 Gazette Issue No. 4970 Gazette Date Shown 21 September 2026 Governing Act Telecommunications Act, 2023 Legal Provision Section 19 Relevant Rule Rule 5 of the Telecommunications (Framework to Notify Standards, Conformity Assessment and Certification) Rules, 2025 Standards Covered TSDSI-transposed 3GPP standards Releases Release 15, 16, 17 and 18 TSG Reference TSG#109 Total Documents 202 Sector Telecommunication equipment Main Regulatory Action Adoption as National Standards Separate Product Compliance Deadline Not expressly specified in this notification Separate Transition Period Not expressly specified in this notification Standards Availability TEC website The Gazette records the notification date as 17 September 2026 and states that the standards are adopted with effect from the date of publication of the notification in the Official Gazette. The Gazette issue itself is dated 21 September 2026.  What Exactly Has TEC Done Through S.O. 5176(E)? The notification is about standards adoption. It says that the Central Government, using powers under Section 19 of the Telecommunications Act, 2023 read with Rule 5 of the 2025 Rules, notifies the identified TSDSI-transposed standards for telecommunication equipment for adoption as National Standards.  Three facts deserve attention. First, this is not just an industry announcement. S.O. 5176(E) has been published in the Gazette of India under the statutory telecom standards framework. Second, the notification deals with a defined standards batch It covers: release 15  Release 16  Release 17  Release 18  Outcome of TSG#109 and  202 documents in total.  Third, the Gazette does not list all 202 standards individually The notification instead directs readers to the TEC website, where the adopted National Standards corresponding to the transposed standards are made available.  So, a compliance team cannot stop after reading the two-page Gazette. The next exercise is to determine which standard, if any, connects with the company's actual product. How Did These 202 Standards Reach the Gazette Stage? The September notification followed an earlier public consultation. TEC's Standardisation Division issued a notice on 6 March 2026 inviting public comments on adoption of TSDSI-transposed 3GPP Release 15–18 standards arising from TSG#109. The consultation covered the same 202 documents and remained open until 6 May 2026.  That process is relevant because Rule 5 of the 2025 Rules requires prior publication of draft standards and draft conformity-assessment measures with a consultation period of at least 60 days before finalisation, subject to limited exceptions provided in the Rules.  Regulatory Timeline Stage Date What Happened TEC consultation opened 6 March 2026 Comments invited on Release 15–18 TSG#109 standards Consultation closed 6 May 2026 End of stated public-comment period Notification dated 17 September 2026 S.O. 5176(E) issued Gazette issue dated 21 September 2026 Notification appears in Gazette No. 4970 This sequence is useful because it shows that the Gazette is the formal adoption stage following the earlier standards consultation. Regulatory Framework Behind the Notification Section 19 of the Telecommunications Act, 2023 Section 19 gives the Central Government power to notify standards and conformity-assessment measures in relation to a range of telecom matters. These include standards concerning: telecommunication equipment  telecommunication networks  telecommunication identifiers  manufacture of telecom equipment  import  distribution  sale  telecom security  cyber security and  certain other technical areas listed in the Act.  S.O. 5176(E) expressly relies on this provision.  Role of the 2025 Standards, Conformity Assessment and Certification Rules The Telecommunications (Framework to Notify Standards, Conformity Assessment and Certification) Rules, 2025 provide the procedural framework used for standards and conformity assessment. Under the Rules, TEC and the National Centre for Communication Security are designated as Appropriate Authorities. Rule 5 deals with notification and review of standards and conformity-assessment measures.  The Rules also define a standard broadly. It can cover characteristics, specifications, Essential Requirements, recommended practices, classifications, test methods and procedures relating to Section 19 of the Act.  This is why the word “standard” should not automatically be read as meaning “a fresh certificate is required for every product.” There are several regulatory steps between having a National Standard and establishing the exact obligation for a particular telecom device. What Are TSDSI-Transposed 3GPP Standards? The wording sounds technical, but it can be understood by separating three ideas: 3GPP, TSDSI, and transposition. What is 3GPP? The 3rd Generation Partnership Project (3GPP) develops technical specifications used for mobile communication systems. Its releases group technical work into organised stages of development. For broad context: Release 15 formed part of the first major 5G standards work  Release 16 extended the 5G framework  Release 17 added further 5G capabilities and vertical-use requirements and  Release 18 introduced the first stage identified with 5G-Advanced.  That does not mean every specification in these releases applies to every piece of telecom equipment. A release may contain specifications for completely different technologies, interfaces, network functions and equipment types. What is TSDSI? Telecommunications Standards Development Society, India (TSDSI) is India's telecom standards development organisation. In the present notification, TEC is not simply reproducing a generic reference to all 3GPP documents. It refers specifically to TSDSI-transposed 3GPP standards. What Does “Transposed” Mean? Put simply, transposition allows specifications developed through an international standards system to be taken into the relevant national standards framework through the recognised standards process. For a business, the practical point is not the word “transposed” itself. The important questions are: Which TSDSI standard number applies?  Which 3GPP specification sits behind it?  Which release/version is involved?  Has TEC adopted that document?  Does the company's product-specific requirement refer to it?  That is the level at which compliance decisions should be taken. What Does Adoption as a National Standard Actually Mean? This is the most important part of the notification. TEC's published standards-adoption policy explains that it adopts domestic and international telecom standards into National Standards. The same policy states that adopted National Standards are voluntary unless they are made mandatory through their use, reference, or adoption in a regulation or Government directive.  At the same time, the 2025 Rules create mandatory obligations where a notified standard applies to a person or telecommunication equipment and a Certificate of Conformity Assessment is required. Rules 7 and 8 deal with those compliance obligations.  These two points need to be read together. The sensible reading for businesses is: Adoption into the National Standards framework is one regulatory step. A separate product-level assessment is still needed to determine whether and how the standard becomes mandatory for particular equipment. This prevents two opposite mistakes. One mistake is to assume that the notification has no regulatory relevance because it concerns standards. The other is to assume that all 202 documents immediately become compulsory testing requirements for every telecom device sold in India. Neither approach is suitable for a product-level compliance decision. What Is Covered Under the 202-Document TSG#109 Set? TEC's current Standards Adoption Policy page provides a release-wise breakdown of the 202 TSG#109 documents. 3GPP Release Number of Documents Release 15 9 Release 16 20 Release 17 55 Release 18 118 Total 202 The figures total exactly 202 and match the total stated in S.O. 5176(E).  This breakdown immediately shows why companies should avoid the phrase “202 requirements for every telecom product.” More than half of the documents in this particular batch fall under Release 18. A product may nevertheless be linked to only a small part of this wider standards set. Understanding Release 15 to Release 18 Without the Jargon Release 15 Release 15 laid important foundations for 5G, including early commercial deployment requirements.  Only 9 documents from Release 15 form part of TEC's TSG#109 batch.  That figure is important. S.O. 5176(E) is not re-adopting every historical Release 15 document as one giant package. Release 16 Release 16 expanded the 5G standards work and addressed the wider set of identified IMT-2020 requirements.  TEC's TSG#109 set includes 20 Release 16 documents.  Release 17 Release 17 is a continued enhancement of earlier 5G work and extends technical coverage into additional use cases.  The TEC list contains 55 Release 17 documents in the TSG#109 batch.  Release 18 Release 18 is associated with the first stage of 5G-Advanced within 3GPP's release structure.  It forms the largest part of the new TEC batch, with 118 documents.  For manufacturers working on newer telecom equipment, this may make Release 18 particularly relevant to a technical standard review. It does not, by itself, prove that all 118 Release 18 documents apply to their product. What Does “Outcome of TSG#109” Mean? TSG refers to 3GPP's Technical Specification Group structure. The reference to TSG#109 is useful because technical specifications continue to move through versions over time. The meeting or plenary cycle helps identify the particular set of specifications taken up for national adoption. In practical terms, a compliance team should not simply write “3GPP Release 18” in its file and consider the work complete. It should identify: the exact specification  TSDSI-transposed document  applicable release  relevant version and  corresponding TEC National Standard.  The details become important when a test report, Essential Requirement, or certification file refers to an exact technical standard. Where Are the 202 National Standards Available? The Gazette itself says that the adopted National Standards corresponding to the TSDSI-transposed standards are available through the TEC website.  TEC's Standards Adoption Policy page also maintains the TSG-wise and release-wise standards information.  For a manufacturer, downloading every document should not be the first action. A better order is: identify the product  identify its regulatory category  locate the applicable Essential Requirement or other TEC requirement  see which technical standards are referenced  compare those references against the newly adopted standards.  This narrows a 202-document exercise into a manageable product-specific review. When Do the New National Standards Take Effect? S.O. 5176(E) says adoption takes effect from the date of publication of the notification in the Official Gazette.  The notification is dated 17 September 2026, while the Gazette issue reproduced in the attached document is dated 21 September 2026.  Businesses should therefore avoid casually treating the date printed below “New Delhi” as the commencement date without checking the publication record. More importantly, this notification does not separately provide: a 30-day implementation period  a 60-day grace period  a 180-day transition  a phased product rollout or  a product-specific compliance date.  If another TEC direction provides such a period for particular equipment, that direction should be read separately. Does S.O. 5176(E) Apply to Every Telecom Product? The Gazette uses the broad expression “telecommunication equipment”, but does not attach a schedule matching each of the 202 standards with individual product categories.  That means a product-level review is necessary. Consider two separate questions: Question 1: Has TEC adopted the standard nationally? For the 202 documents identified in the notification, yes. Question 2: Does that particular standard create a mandatory conformity-assessment obligation for this exact product? That cannot be answered merely from the two-page Gazette. The 2025 Rules themselves use the expression “every person to which a notified standard applies” when setting out conformity-assessment duties. Rule 8 similarly deals with telecom equipment to which a standard applies.  Those words make applicability a necessary part of the compliance analysis. Are All 202 Standards Mandatory for Every Manufacturer or Importer? No blanket statement of that nature appears in S.O. 5176(E). TEC's standards-adoption policy says National Standards adopted under its process remain voluntary unless made mandatory through regulation, Government direction or their regulatory use/reference.  At the same time, the 2025 Rules make conformity assessment compulsory where an applicable notified standard and corresponding conformity-assessment obligation apply.  Therefore, manufacturers and importers need to find the regulatory link between: Product → Applicable Requirement → Standard → Conformity Assessment → Certification Without that link, saying “all 202 are mandatory for us” can lead to unnecessary compliance work. National Standard vs Essential Requirement vs MTCTE Certification These terms are often used as though they mean the same thing. They do not. Term Simple Meaning Position Relevant to This Notification National Standard Standard adopted into India's telecom standards framework 202 documents have been adopted Essential Requirement Set of parameters, standards, specifications or requirements notified for relevant equipment Product-specific ER needs to be checked Conformity Assessment Process used to demonstrate compliance with applicable standards Governed by the 2025 Rules Product Testing Technical testing against prescribed parameters Depends on applicable requirement Certificate of Conformity Assessment Certification following the applicable conformity-assessment framework Required where the relevant framework applies MTCTE Mandatory Testing and Certification of Telecommunication Equipment framework Applicability must be checked by product Retesting Fresh testing after an earlier test Not generally ordered by S.O. 5176(E) Re-certification Obtaining another certificate where required No blanket direction appears in S.O. 5176(E) TEC describes Essential Requirements as the requirements against which Mandatory Testing and Certification of Telecommunication Equipment is carried out.  That is why an ER check is far more useful than assuming that every newly adopted National Standard automatically demands an MTCTE application. Does the Notification Change MTCTE Requirements? What the Gazette Actually Says S.O. 5176(E) states that the specified TSDSI-transposed 3GPP standards are adopted as National Standards. It does not contain: a revised MTCTE product schedule  revised Essential Requirements  a new MTCTE application form  fresh certification fees  a universal retesting requirement  a product-wise mandatory date or  an instruction cancelling every existing certificate.  What MTCTE Requires Separately The current MTCTE portal states that telecommunication equipment notified under MTCTE cannot be sold, deployed in a telecom network, or otherwise used in India without a valid Certificate of Conformity Assessment in accordance with the prescribed Essential Requirements.  Therefore, an affected company should check: Is the product notified under MTCTE?  Which ER applies?  Has the ER recently changed?  Does the ER reference one of the newly adopted standards?  Has TEC issued a product-specific instruction?  Does an existing test report remain usable?  Is a certificate modification required?  Is a transition arrangement available?  This is where TEC compliance services become relevant for businesses that have several models, imported products, or overlapping technical standards and cannot safely make the decision from the Gazette alone. Why a Product-Specific Notification Looks Different An earlier Phase VI MTCTE notification helps shows the difference. That notification expressly identified specified telecom equipment, mapped those products to Essential Requirements, provided a 180-day implementation period, and restricted import, sale, distribution or use after the applicable date unless MTCTE requirements were met.  S.O. 5176(E) does not contain that type of product schedule or 180-day clause. This comparison is useful because it shows why a National Standards adoption notification should not be rewritten as if it were itself a product-phase MTCTE notification. How Manufacturers Can Check Whether a New Standard Applies There is no need to start with a 202-document spreadsheet. Start with the product. Step 1: Identify the Exact Product Record: commercial product name  model number  product family  hardware version  software/firmware version, where relevant  interfaces  wireless/network technologies supported.  Step 2: Check the TEC/MTCTE Category Identify whether the equipment is covered by an existing mandatory testing and certification category. Step 3: Find the Current Essential Requirement Check the current ER number and version. Do not rely on an old certificate or test report without checking whether the ER has since been revised. Step 4: Read the Referenced Technical Standards Identify the TSDSI, 3GPP, TEC, ETSI, ITU, BIS, or other standards incorporated into the applicable requirement. Step 5: Compare with the TSG#109 Set Check whether one of the newly adopted standards corresponds with the reference in the product's regulatory requirement. Step 6: Check for a Separate TEC Direction Look for: ER revision  testing instruction  exemption  transition circular  certificate-modification instruction  acceptance of overseas test reports  implementation date.  Step 7: Decide the Actual Action Only then decide whether the business needs: no immediate change  document update  technical review  further testing  certificate modification  fresh certification or  monitoring only.  Why Standard Version Mapping Matters A telecom standard is not just a name. Version control matters because specifications are revised through later technical meetings and releases. A company's internal compliance sheet should ideally record: Item What to Record Product Exact model/family TEC Category Applicable product category ER Number and current version Standard Exact National Standard/reference 3GPP Specification Corresponding specification number Release Release 15/16/17/18 Version Exact applicable version Test Report Standard/version used Certificate Relevant certificate ID/status Latest TEC Direction Circular/notification checked A mismatch at this stage can create practical problems later. A supplier may refer to one release, a test laboratory another, and the certification file a third. That is much harder to correct after an application has already moved into assessment. What Telecom Manufacturers Should Review Now Manufacturers do not need to treat the Gazette as an instruction to rebuild every product. A targeted review is more sensible. Product Portfolio Separate products into: products currently covered under MTCTE  products under certification  new products under development  products not currently covered by a relevant certification requirement.  Technical Documentation Check whether current documents still refer to the correct standards. This may include: product specification sheets  compliance matrices  declarations  internal design records  test plans  test reports.  Existing Certification Compare the certified model and its applicable ER against current TEC records. Do not assume that adoption of a later standard automatically invalidates an existing certificate. Products Under Development For future models, standards mapping can be done earlier in the design cycle. This is often easier than changing technical documentation immediately before testing. What Telecom Importers and Foreign OEMs Should Check Imported products need an additional layer of coordination because the technical design and test files may be controlled by the overseas OEM. Importers should obtain clear information on: exact product model  variant  hardware configuration  relevant software version  technical standard used by the manufacturer  existing Indian certificate  test reports  applicable ER  authorised Indian representative details, where applicable.  A commercial invoice that says only “telecom device” is not enough to decide whether a particular 3GPP National Standard affects the equipment. For companies bringing telecom products into India, importer compliance services and TEC compliance services may therefore involve both regulatory classification and technical document matching before a certification or shipment decision is taken. What Existing TEC or MTCTE Certificate Holders Should Check Businesses holding an existing certificate should avoid two quick reactions: “Nothing has changed for us.” and “Every certificate must now be renewed.” Both can be wrong depending on the product. Instead, review: Has the Essential Requirement changed? If no relevant ER has changed, the standards adoption may not immediately alter the existing certification position. Does the ER now reference a different standard? If yes, check the implementation and transition instructions. Has TEC asked for retesting? Do not infer this. Find the actual direction. Has the model changed? Hardware, software, interfaces, or product configuration may affect the analysis independently of S.O. 5176(E). Does an exemption apply? Rule 9 of the 2025 Rules contains conformity-assessment exemptions for specified circumstances and also addresses cases where recertification is not required.  The exact facts should be checked before relying on an exemption. Is Fresh Testing Required? S.O. 5176(E) does not contain a general direction ordering fresh testing of every product covered by Releases 15 to 18. Testing should instead be checked against: applicable Essential Requirement  notified conformity-assessment measure  revised standard  test parameters  separate TEC circular  transition instruction  existing test-report acceptance rules.  TEC's current MTCTE page also lists product-specific exemptions, test-report acceptance directions, and technical clarifications, which shows that testing treatment can vary between product groups and parameters.  That is another reason to avoid a blanket retesting recommendation. Is Re-Certification Required? Again, not automatically. The 2025 Rules expressly provide situations where recertification is not required, including where the model or brand is not different from the equipment already certified, subject to the relevant conditions in Rule 9.  S.O. 5176(E) does not separately state: All equipment certified against an earlier standard must obtain a fresh certificate. Without such a direction, a certificate holder should first establish whether its product's applicable regulatory standard has actually changed in a manner requiring action. Is There a Transition Period? The notification itself does not set out a separate transition period. It does not mention: 30 days  60 days  90 days  180 days  an old-stock cut-off  grandfathering  concurrent operation or  an expiry date for earlier versions.  Rule 5 of the 2025 Rules does permit TEC or the relevant Appropriate Authority to allow an amended or revised standard to operate concurrently with the existing standard for a stated period through an order.  That power does not mean a transition period should be invented for S.O. 5176(E). If TEC issues a separate order for a particular standard or product, businesses should follow that document. What Happens to Earlier Standards? The Gazette does not contain a blanket sentence stating that all earlier TSDSI/3GPP National Standards have been withdrawn. Neither does it include a table saying: Earlier Standard Replaced by Withdrawal Date Because that information is absent, companies should check the current TEC standards record before marking an existing standard as obsolete. A later technical version does not automatically tell a compliance team: when the earlier version stops applying  whether both versions can operate together  whether existing certificates remain valid  whether existing test reports are accepted.  Those questions need the relevant regulatory document. Impact on Telecom Testing Laboratories Testing laboratories are another stakeholder group that may need to watch this standards batch closely. The immediate impact may be a standards-mapping review rather than an automatic change in accreditation or recognition. Laboratories may need to check: new standard versions  test-method references  ER revisions   test scope  equipment capability  reporting references  recognised CAB scope.  The 2025 Rules permit the Appropriate Authority to recognise Conformity Assessment Bodies for carrying out conformity assessment against standards notified under Section 19.  S.O. 5176(E), however, does not itself tell every testing laboratory to seek fresh recognition. Impact on Procurement and Vendor Management This part is easy to miss because the notification is usually read by regulatory teams first. But standards reference also appear in: purchase specifications  tenders  supplier qualification documents  technical agreements  OEM declarations.  Procurement teams should therefore avoid copying an old standards clause into a new tender without checking the current reference. Likewise, inserting “latest 3GPP Release 18” into every procurement document without understanding the product requirement may create an unnecessary commercial condition. Legal compliance and contractual requirements should remain separate. A buyer can choose a stricter technical specification commercially, but that does not make the specification a statutory requirement. Impact on Product Development and Engineering Teams For engineers, the update is mainly about keeping technical references under control. During Product Design Check whether the equipment uses functions or interfaces linked with newly adopted specifications. Before Testing Make sure the regulatory team and laboratory are working with the same standard number and version. Before Certification Confirm that: product model  ER standard  test report and  application details  all match. After Certification Maintain a change-control record so that later hardware, firmware, or model changes can be compared against the certified configuration. This is a practical control, not a separate legal form created by S.O. 5176(E). What the Notification Does Not Tell Businesses Because the Gazette is only two pages, several questions are simply outside its text. Question What S.O. 5176(E) Says Which of the 202 standards applies to each product? Not expressly specified Must every product be retested? Not expressly specified Must every certificate be renewed? Not expressly specified Is there a new application form? Not specified Is there a new certification fee? Not specified Is there a laboratory fee? Not specified Is there a product-wise implementation deadline? Not specified Is there a transition period? Not specified Are old standards automatically withdrawn? Not specified Is existing stock grandfathered? Not specified Is every MTCTE ER revised? Not stated Is every importer required to file a fresh application? Not stated Are new penalties created by S.O. 5176(E)? Not specified Does it contain a product schedule? No product-wise schedule is reproduced This does not mean those matters are absent from the wider telecom regulatory framework. It means they should not be attributed to this notification without another supporting official source. Compliance Risks Businesses Should Avoid The bigger risk here may be a wrong interpretation rather than simply missing the Gazette. Treating All 202 Standards as One Product Requirement A manufacturer could spend time reviewing documents that have no connection with its equipment. Better approach: first identify the product and relevant ER. Continuing With an Old Standards List Without Review The opposite approach is also risky. A business may keep using technical references copied from an older file without checking current standards. Better approach: review the version before new testing or certification work begins. Asking for Retesting Before Establishing Applicability Fresh testing can cost time and money. Better approach: confirm that the applicable ER or official direction requires it. Assuming an Existing Certificate Has Become Invalid S.O. 5176(E) does not contain a general cancellation clause. Better approach: review certificate status and the product-specific requirement. Confusing a Procurement Standard with a Legal Requirement A customer contract may demand something beyond regulatory minimums. Better approach: clearly mark the difference between contractual requirements and statutory requirements. Business Impact by Stakeholder Stakeholder Likely Immediate Impact Main Review Telecom manufacturers Technical standards mapping Product, ER and standard version Importers Supplier and Indian compliance-document check Model, certificate and applicable ER Foreign OEMs India-specific standards alignment Technical file and AIR support Existing certificate holders Review rather than automatic re-certification Technical file and AIR support Testing laboratories Standards and test-scope review Applicable parameters and versions Telecom operators Procurement-specification review Technical and regulatory references. Engineering teams Version-control work Product design and standards mapping. Compliance teams Legal applicability assessment Standards, ERs, MTCTE and transition directions The cost and effort will not be identical for all these stakeholders. A business with a single unaffected product may need only a documented review. A manufacturer with several 5G-related products, multiple certificates and active applications may need a much deeper exercise. Costs and Operational Challenges S.O. 5176(E) does not prescribe a fee. It also does not say that all affected businesses must incur fresh laboratory or certification charges. Costs may nevertheless arise where a product-specific assessment identifies further work. Possible cost areas include: Internal Technical Review Engineering and regulatory teams may need time to match products with the correct standards. Supplier Coordination An Indian importer may need revised technical material from a foreign OEM. Documentation Changes Internal compliance matrices, declarations, or procurement specifications may need correction. Testing A laboratory cost may arise if the applicable regulatory requirement actually calls for new testing. Certification Application or certification costs should be considered only where a fresh or modified certification process is genuinely applicable. Do not budget for all five categories automatically. Compliance Checklist for Manufacturers and Importers Priority Check Action High Exact product/model Confirm regulated product identity High MTCTE coverage Check current notified product list High Applicable ER Verify current ER and version High Standard reference Match with TEC National Standard High Release/version Check correct TSDSI/3GPP version High Existing certificate Confirm current validity and model coverage Medium Existing test report Match standard/version and ER Medium Transition direction Search for a separate TEC order Medium Foreign OEM records Check technical consistency Medium Procurement documents Update outdated references where required Ongoing TEC circulars Track subsequent directions The checklist should be recorded in the company's compliance file, particularly where the final conclusion is that no immediate certification action is required. That record can later show why the business reached its decision. What Businesses Should Do Next 1. Do not start with all 202 standards Start with the products currently manufactured, imported, sold or being developed. 2. Check the latest TEC product requirement Find the current Essential Requirement and applicable certification position. 3. Map technical references Compare the ER and test-report standards with the newly adopted TSG#109 documents. 4. Separate an adopted standard from a mandatory certification requirement This single step can prevent unnecessary filing and testing. 5. Review existing certificates carefully Look for actual TEC directions affecting their continued validity. 6. Speak with the OEM or laboratory where technical information is missing A regulatory team should not guess the specification version used by an overseas manufacturer or test laboratory. 7. Keep evidence of the revie w Record: source checked  ER version  standard  certificate  TEC circulars reviewed  conclusion  date of review.  8. Monitor further TEC updates National Standards can later be reflected in product-specific requirements. The internal file should therefore be revisited when the relevant ER or certification instruction changes. How Corpseed Can Help with TEC Compliance Reading S.O. 5176(E) is straightforward. Deciding what it means for a specific router, network element, terminal, radio product, or other telecom equipment can take more work. Corpseed's TEC compliance services can support manufacturers, foreign OEMs, and importers in checking the regulatory position before they begin unnecessary testing or filing. Depending on the product, the support may include: TEC applicability assessment: checking whether a product falls within an existing regulated category  product-to-standard mapping: matching equipment with the relevant TEC, TSDSI or referenced technical standard  Essential Requirement review: identifying the current ER and checking the standards referred to in it  MTCTE applicability assessment: establishing whether mandatory testing and certification apply  TEC certification support: assisting where a certificate is actually required  MTCTE certification services: supporting application and document preparation for notified equipment  technical document review: checking model details, test reports, standard numbers and regulatory records for consistency  testing coordination: assisting with recognised laboratory testing where the applicable requirement calls for it  existing certificate review: checking whether a regulatory update requires modification, fresh assessment or no immediate action  importer compliance support: reviewing the relationship between the imported model, overseas OEM documentation and Indian telecom requirements  compliance gap assessment: identifying missing or outdated regulatory records and  ongoing telecom regulatory monitoring: tracking relevant TEC and DoT notifications for the product.  A TEC compliance consultant should first answer the applicability question rather than starting with an assumption that certification is required. For businesses handling several telecom products, this can make the difference between a focused compliance exercise and a costly review of standards that do not apply to their equipment. What Further TEC Updates Should Companies Monitor? The publication of a National Standard does not end the compliance review. Companies should monitor the official TEC and MTCTE channels for: revised Essential Requirements  product-specific conformity-assessment measures  MTCTE phase notifications  implementation dates  transition orders  revised test parameters  laboratory-related directions  test-report acceptance conditions  certification amendments  withdrawal or replacement of earlier standards.  The key is to watch for the point at which a technical standard update becomes relevant to the company's actual equipment. Key Takeaways The TEC TSDSI 3GPP standards 2026 notification brings a defined group of updated telecom specifications into TEC's National Standards framework. S.O. 5176(E) is dated 17 September 2026 and has been issued by the Ministry of Communications, Department of Telecommunications through TEC.  It adopts TSDSI-transposed 3GPP Release 15-18 standards connected with TSG#109.  The batch contains 202 documents.  TEC's standards page breaks these into 9 Release 15, 20 Release 16, 55 Release 17, and 118 Release 18 documents.  The Gazette does not contain a product-by-product applicability schedule.  It does not state that every existing telecom product requires fresh testing.  It does not contain a general direction requiring every MTCTE certificate to be renewed.  Product-specific Essential Requirements and other TEC directions should be checked before a compliance decision is taken.  Manufacturers and importers should map the product, ER, standard and certification requirement before spending on testing or filing.  Businesses that need help with the product-level assessment can use TEC compliance services to determine what is actually applicable rather than treating all 202 standards as one compliance obligation.

Subject

Summary: Manipur has proposed an important change in the way shops and establishments may be registered. The Manipur Shops and Establishments (Regulation of Employment and Conditions of Service) (Amendment) Bill, 2026, introduced as Bill No. 14 of 2026, seeks to amend the existing Shops and Establishments law in the State. The Bill focuses mainly on Chapter II and Section 5 of the principal Act. The change is aimed at a practical problem: businesses may sometimes need more than one registration or licence for a similar compliance purpose. The State has linked the proposal with Compliance Reduction and Deregulation Phase II, under which overlapping licensing requirements are being reviewed. For employers, the biggest question is whether this means Shops and Establishments registration is being removed. The answer from the Bill is more limited. The proposal does not say that registration disappears. Instead, the proposed Section 5 says that every employer of a shop or establishment must get it registered under any law for the time being in force. Manipur Shops and Establishments Amendment Bill 2026 at a Glance Particular Details State Manipur Document Amendment Bill Bill Number Bill No. 14 of 2026 Bill Title Manipur Shops and Establishments (Regulation of Employment and Conditions of Service) (Amendment) Bill, 2026 Principal Law Manipur Shops and Establishments (Regulation of Employment and Conditions of Service) Act, 2021 Main Area Changed Chapter II and Section 5 Main Purpose Reduction of dual or overlapping licensing Proposed Registration Rule Registration under any law for the time being in force Main Stakeholders Employers of covered shops and establishments Separate Transition Period Not expressly specified Proposed Commencement From publication of the enacted Act in the Official Gazette Present Document Status Bill / proposed amendment The principal Act was enacted to regulate employment and other service conditions of workers in shops and establishments. What Is the Manipur Shops and Establishments Amendment Bill, 2026? The 2026 Bill is a targeted amendment rather than a complete replacement of Manipur's Shops and Establishments law. Its central focus is registration. The State wants to deal with a situation where a business may be required to complete more than one registration or licensing process even though the nature of the compliance is similar. The Bill says such overlap can: delay the start of business operations, add to administrative work, increase the compliance burden, create unnecessary procedural hurdles for entrepreneurs.  The proposed solution is to change the registration wording under Section 5. Instead of creating or retaining a separate overlapping requirement, the Bill proposes allowing a shop or establishment to be registered under a law that is already in force. That does not mean every registration automatically becomes acceptable. That point needs separate clarification from the competent authority Bill vs Act: Has the New Rule Already Started? No. The attached document is an Amendment Bill. That is an important legal distinction. A Bill contains a proposal for changing the law. A business should not treat every clause in a Bill as an already-operative legal requirement. The document states that, once enacted, the legislation would be called the Manipur Shops and Establishments (Regulation of Employment and Conditions of Service) (Amendment) Act, 2026. It also says that the Act would come into force from the date of publication in the Official Gazette.  So four stages should not be mixed up: introduction of the Bill, legislative consideration, enactment, commencement through Gazette publication as provided in the Bill. For an employer, this means an existing registration should not be cancelled merely because the amendment has been proposed. Why Has Manipur Proposed This Change? The Statement of Objects and Reasons gives a fairly direct explanation. 1. To Reduce Duplicate Licensing The Government has identified situations where businesses may be required to obtain multiple licences for similar compliance requirements. The Bill links this issue with the Manipur Compliance Reduction and Deregulation Phase II exercise.  The objective is therefore not to remove every registration. It is to reduce duplication. 2. To Reduce Delays in Starting a Business: The Bill says overlapping licences can slow the process of starting a business. For a new establishment, every extra licence may involve: another application, another document set, another internal approval, another follow-up, another compliance deadline. Removing an unnecessary duplicate requirement can reduce this burden. 3. To Reduce Routine Administrative Work: The Bill also points to the administrative side of compliance. If government officials spend less time dealing with repetitive licensing work, resources can be used elsewhere. 4. To Focus More on Wage and Workplace-Safety Violations: The Bill specifically says regulatory resources could be directed towards genuine infringements involving wage laws and workplace safety rather than routine administrative approvals. This is why the amendment should not be read as weakening labour protection. The stated approach is closer to: less paperwork, but continued enforcement of substantive labour duties. Regulatory Framework Behind the Amendment The Bill seeks to amend the Manipur Shops and Establishments (Regulation of Employment and Conditions of Service) Act, 2021, referred to in the document as Manipur Act No. 9 of 2023.  That law deals with workers employed in shops and establishments and regulates their employment and conditions of service. The 2026 amendment is narrower. It does not rewrite: the entire employment framework, all worker protections, all employer obligations, every registration or licence connected with a business. It deals specifically with the registration framework under Chapter II, and Section 5. What Is Dual Licensing? Dual licensing, in the context of this Bill, means a business may have to obtain more than one licence or registration for a similar compliance purpose. This does not mean every business licence is a duplicate. For example, a fire-related approval and a tax registration serve different purposes. One cannot automatically replace the other. The problem arises when two approvals effectively cover the same administrative requirement. The Bill identifies this kind of overlap as a source of unnecessary compliance work. What Has Changed Under the Proposed Amendment? The Bill proposes two direct legislative changes. Change 1: New Title for Chapter II The title of Chapter II is proposed to be replaced with: “REGISTRATION OF A SHOP OR AN ESTABLISHMENT.”  This clearly places the Chapter around the registration of shops and establishments. Change 2: Section 5 to Be Substituted The existing Section 5 is proposed to be replaced. The new provision states that every employer of a shop or establishment shall get the shop or establishment registered under any law for the time being in force.  This is the main operative proposal in the Bill. Section 5 Explained in Plain Language The proposed provision is short, but its wording has practical importance. “Every Employer” The provision places the responsibility on the employer. So the amendment does not remove employer responsibility for registration. “Shop or Establishment” The requirement applies to establishments falling within the scope of the principal legislation. The Bill itself does not repeat every statutory definition, exclusion or threshold from the principal Act. Therefore, businesses should check applicability under the main law where necessary. “Registered Under Any Law” This is where the real change lies. The wording suggests that the Government does not necessarily want a separate registration where an establishment is already properly registered under another applicable law. This is consistent with the stated purpose of reducing overlapping licensing. “For the Time Being in Force” The relevant registration must arise under a law that is legally in force. An expired, withdrawn or otherwise inapplicable registration would not automatically satisfy this wording. Does “Any Law” Mean GST, Udyam or Trade Licence? The attached Bill does not say so. This is probably the most important point for businesses. The Bill does not contain a list saying that the following registrations will automatically satisfy Section 5: GST registration, Udyam registration, municipal registration, trade licence, professional tax registration, another labour registration, any particular business certificate. It would therefore be risky to make a general claim that one of these registrations definitely replaces Shops and Establishments registration. The law uses broad language, but the operational interpretation still needs clarity. Does the Bill Abolish Shops and Establishments Registration? No such complete abolition is stated. The proposed Section 5 still requires a shop or establishment to be registered. The important change is that registration may be recognised under another law in force, subject to how the final framework is implemented. This can be understood through a simple distinction: Question Position Is registration completely removed? No such provision appears in the Bill Is Section 5 being changed? Yes Is the registration approach being broadened? Yes, under the proposed wording Does the Bill list accepted substitute registrations? No Are other labour duties removed? No such general removal is stated This is why calling the proposal an “abolition of Shops registration” would be misleading. Existing Framework vs Proposed Position Compliance Area Existing Position Proposed Position Likely Business Meaning Chapter II Existing Chapter structure Renamed around registration of shops/establishments Registration remains central Section 5 Existing provision Complete substitution proposed Registration rule changes Registration approach Existing framework Registration under any law in force Potential reduction in duplication Dual licensing Identified as a concern Intended to be reduced Fewer overlapping approvals may be needed Wage compliance Continues under applicable laws Not removed Employer duties remain Workplace safety Continues Not removed Substantive compliance remains The attached Bill does not reproduce the complete earlier wording of Section 5. A detailed comparison of old and new text should therefore be made only after checking the principal Act. Scope and Applicability The amendment principally concerns employers of shops and establishments covered by the principal Act. That may include several commercial and service establishments operating in Manipur. However, the Bill does not reproduce: every statutory definition, every exemption, employee thresholds, sector-specific exclusions, special-category treatment. Therefore, the safest approach is to first check whether the establishment falls under the principal Act. The Bill should not be presented as applying automatically to every business in Manipur. Who May Be Affected? The proposed changes may affect businesses differently depending on whether they are already operating in Manipur or are planning to start there. Existing registrations, new applications and internal compliance work may all need to be reviewed. 1. Existing Shops and Establishments: Existing businesses will mainly want clarity on what happens to their current registration. Questions may include: Does the present certificate remain valid? Will renewal still be required? Will another registration become sufficient? Will an existing registration need to be surrendered? The Bill does not expressly answer these questions. 2. New Businesses: New establishments may benefit if the amendment removes a separate registration step. However, that benefit depends on how the final system is implemented. 3. MSMEs: MSMEs may be among the businesses most affected by duplicate paperwork because many smaller firms do not have dedicated legal or compliance teams. If one overlapping process is removed, the internal effort involved in setting up or maintaining compliance may reduce. 4. Startups: A startup entering Manipur may need to deal with several registrations at the initial stage.  A more rational registration structure can make compliance planning easier. However, the Bill does not promise a particular cost saving or shorter processing time. 5. HR and Compliance Teams: For established organisations, the amendment will mainly require a review of existing registration records and internal SOPs. Impact on MSMEs and New Businesses The stated objective of the Bill is closely linked to ease of compliance. For smaller businesses, a duplicate registration can create more than a filing burden. It may also require coordination between: promoters, accountants, HR teams, legal teams, consultants, government departments. Reducing one repetitive step could therefore have practical value. Possible benefits include: Lower Administrative Work: Less duplication may mean fewer repetitive forms, and records. Easier Business Setup: The Bill itself says overlapping licences can delay business commencement. Better Internal Compliance Management: A simpler registration structure makes it easier to identify what is actually required. Lower Risk of Duplicate Filings: Where two registration mechanisms cover the same purpose, one can easily be missed or renewed late. Reducing overlap may make compliance easier to track. These are likely practical benefits, not guaranteed outcomes written into the Bill. Will Other Labour Compliances Still Apply? Yes, wherever those obligations continue under the relevant law. The Bill is about a registration provision. It does not say that employers can stop following requirements relating to: wages, working conditions, employee safety, statutory records, working hours, leave, employment conditions, other provisions of the principal Act, other applicable labour laws. The legislative reasoning actually says that reduced licensing work could help authorities focus on wage-law violations and workplace safety.  That makes the policy intention fairly clear. Registration Simplification vs Labour Compliance Compliance Area Effect of the Proposed Amendment Establishment registration Proposed to be simplified Duplicate registration Intended to be reduced Wage compliance No removal stated Workplace safety No removal stated Employment conditions No general removal stated Other applicable business licences Continue under their respective laws Other labour-law obligations Continue where legally applicable A registration amendment should therefore not be treated as a general exemption from labour law. What Happens to Existing Registrations? The Bill does not create a detailed migration mechanism. It does not expressly mention: automatic cancellation, automatic surrender, replacement certificates, conversion of registration, migration from one portal to another, treatment until expiry, renewal exemption, refund of fees, reissue of registration numbers. Until these points are clarified, businesses should avoid cancelling an existing registration based only on the Bill. Is There Any Transition Period? No separate transition period is expressly stated in the attached Bill. The commencement clause instead provides that the amended Act would come into force from the date of its publication in the Official Gazette.  There is no separate period in the Bill such as: 30 days, 60 days, 90 days, one renewal cycle, a migration window. If a transition arrangement is eventually introduced, it would need to come from the final legal or administrative framework. When Will the New Registration Rule Apply? Businesses should keep the Bill’s introduction, enactment and actual commencement date separate. The introduction of the Bill only marks the start of the legislative process. It must first complete the required process before becoming law. The Bill states that the amended Act will come into force from the date of its publication in the Official Gazette. This means the date on which the Bill was introduced should not be treated as the date when the new registration rule starts. What the Bill Clearly Says and What It Leaves Open Issue Position Dual licensing is a concern Clearly stated Chapter II is being amended Clearly stated Section 5 is proposed to be replaced Clearly stated Registration under another law may be recognised Reflected in proposed wording Which registrations qualify Not expressly listed Treatment of existing certificates Not expressly addressed Migration procedure Not expressly addressed Renewal treatment Not expressly addressed Portal changes Not expressly addressed New forms Not expressly addressed Transition period Not expressly addressed Intimation to labour authority Not expressly addressed This is one of the areas where a regulatory compliance consultant can add value after the final law and implementing instructions are available. Practical Questions Employers May Need Answered Once the amendment is enacted and implemented, businesses may need clarity on matters such as: Which Registration Will Be Accepted? The Bill uses broad wording but does not provide a schedule of accepted registrations. Will Existing Shops Registration Remain Valid? No specific transition rule is provided in the Bill. Will Renewal Still Be Necessary? The Bill does not expressly answer this. Will Businesses Need to Inform the Department? No intimation requirement is stated in the attached amendment. Will a Portal Change Be Required? No online process is described in the Bill. Will Supporting Proof Be Required? The proposed text does not explain what documentary proof would need to be maintained. These are implementation matters that should be checked before making any compliance change. What Employers Should Avoid Doing Prematurely The proposal may change the registration process, but employers should not make changes based only on the Bill being introduced. Employers should avoid: Cancelling an existing registration only because the Bill has been introduced. Assuming GST registration automatically replaces Shops registration. Assuming Udyam registration automatically qualifies as a substitute. Treating a trade licence as an automatic replacement without confirmation. Stopping existing renewals without checking whether the current requirement still applies. discontinuing wage or workplace-safety compliance, treating all business licences as merged, changing internal compliance SOPs before the legal position is clear. Potential Benefits for Businesses The amendment can have practical benefits if implemented with clear administrative guidance. Fewer Duplicate Registrations: This is the central benefit identified by the policy reasoning. Reduced Paperwork: A business may have fewer repetitive documents and applications to maintain. Easier Entry for New Establishments: Where registration duplication previously slowed setup, simplification may reduce delays. Better Use of Compliance Resources: Businesses may spend less time on administrative repetition and more time on genuine legal obligations. More Focused Regulatory Enforcement: The Government itself says reducing routine approvals may allow greater attention to wage and safety violations.  Possible Implementation Challenges Even if the amendment is short, businesses may still have some questions when it is put into practice. Identifying Which Registration Counts: Businesses will need to know which registration can be used under the new system. Treatment of Existing Certificates: Employers will need to know whether their current certificate will continue or whether it will no longer be needed. Alignment Between Departments: If different registrations are going to be recognised, government databases and processes may need to align. Internal Confusion: HR teams may mistakenly assume that simplifying registration means other labour duties are also relaxed. Need for Regulatory Clarification: Businesses may need an official circular, rules amendment or administrative guidance before making changes to existing compliance. Business Perspective For businesses, the proposal is mainly about reducing repeat compliance. The likely advantages are straightforward: less duplication, fewer administrative approvals, lower internal workload, easier tracking of registrations. The main concern is equally clear: Which existing registration will actually satisfy the amended requirement? Until this is answered, many businesses may prefer to retain their current setup. Regulatory Perspective From the Government's side, the amendment is meant to reduce time spent on routine licensing. The Statement of Objects and Reasons says this may allow the Department to focus on areas such as: wage-law violations, workplace safety, genuine non-compliance, substantive labour enforcement.  That makes the intention behind the proposal more administrative than deregulatory. Is This Deregulation or Compliance Simplification? The change is better understood as a move to simplify compliance rather than remove labour regulation. The Bill does not remove the labour laws that apply to businesses. Instead, it proposes to reduce the need for separate or repeated registration requirements. Businesses would still have to follow the other labour-related requirements that apply to them. A simpler registration system does not mean a lower standard of employment compliance.. Does the Amendment Create Additional Government Expenditure? The Financial Memorandum states that once the proposed legislation is enacted, there will be no expenditure from the Consolidated Fund of the State.  This statement relates to government expenditure. It should not be read as confirmation that businesses will incur no costs under the changed framework. The Bill does not provide any calculation of private compliance costs or savings. What Businesses Should Do Next The Bill is still a proposal. Until the position changes, businesses should follow the registration requirements that apply to them now. Step 1: Check Applicability Confirm whether the principal Shops and Establishments law applies to the business. Step 2: Keep Existing Registration Records Keep the existing registration papers, including: registration certificate renewal records application details registration number letters or emails received from the department Step 3: List Other Registrations Prepare a list of all current statutory registrations held by the establishment. Step 4: Check the Status of Bill No. 14 of 2026 Keep track of Bill No. 14 of 2026, and check if it has been passed. Step 5: Check the Gazette The proposed Act says that it will start from the date it is published in the Official Gazette. The Gazette will confirm when the change actually takes effect. Step 6: Check for New Instructions After the Bill becomes law, check whether the authorities issue any: notifications circulars amended rules FAQs portal instructions departmental orders Step 7: Check Which Registration Can Be Used Do not assume that GST, Udyam, a trade licence or another certificate will replace the Shops registration. Wait for the final position, or official clarification. Step 8: Keep Up with Existing Labour Compliance Until the new position is clear, businesses should continue with their wage, employment and workplace-safety compliance. Step 9: Update SOPs Only after the final position is clear should internal HR and compliance processes be revised. Practical Compliance Checklist Review Area Recommended Action Priority Applicability of principal Act Verify whether establishment is covered High Existing Shops registration Keep records intact High Current renewal Continue unless officially changed High Other business registrations Prepare complete list Medium Final legislative status Monitor High Gazette commencement Verify High Accepted substitute registration Confirm officially High Labour compliance Continue High Wage obligations Continue High Workplace safety Continue High Internal SOP Change after confirmation Medium How Corpseed Can Help The proposed amendment may simplify registration, but businesses will still need to understand how the final rule fits with their existing licences and registrations. Corpseed's regulatory compliance services can support shops, establishments, MSMEs and growing businesses with: 1. Applicability Assessment Corpseed can review whether the Manipur Shops and Establishments framework applies to the business and its operations. 2. Existing Registration Review: A review can identify: registrations already held, registrations due for renewal, overlapping registrations, potential compliance gaps. 3. Business Registration Mapping Different businesses may hold several licences under different laws. Corpseed can help map these registrations so the business can understand which approvals serve separate purposes and which may overlap. 4. Compliance Gap Assessment A regulatory compliance consultant can review whether existing practices match the applicable registration and labour-law requirements. 5. Business Licence Registration Services Where a licence or registration continues to be legally required, Corpseed can assist with documentation and filing support. 6. Compliance Advisory Services Businesses may need interpretation support once the final Act and implementation instructions are issued. 7. Ongoing Compliance Support For organisations managing several locations or registrations, ongoing compliance support can help track: renewals, regulatory amendments, departmental clarifications, changes in registration requirements. The aim of professional support should not be to create more paperwork. It should help the business identify what is genuinely required and avoid both missing a legal obligation and maintaining an unnecessary duplicate registration. Key Takeaways Manipur has introduced Bill No. 14 of 2026 to amend its Shops and Establishments framework. The proposal focuses mainly on Chapter II, and Section 5. The policy objective is to reduce overlapping, or dual licensing.  The proposed Section 5 still contains a registration requirement. The Bill allows registration under any law for the time being in force, but it does not list which registrations will qualify.  Existing registrations should not be cancelled merely because the Bill has been introduced. Other labour-law duties are not stated to be removed. No separate transition or migration period is expressly provided. The proposed Act would come into force from the date of its publication in the Official Gazette after enactment.  Businesses that are unsure about applicability, overlapping registrations, or the next steps can seek professional compliance support before changing their existing registrations.

Subject

Summary: The Ministry of Agriculture and Farmers Welfare has issued S.O. 5105(E), dated 17 September 2026, laying down specifications for Phosphogypsum (Granular) manufactured for commercial trials. The Order has been issued by the Department of Agriculture and Farmers Welfare under clause 20A of the Fertiliser (Inorganic, Organic or Mixed) (Control) Order, 1985. It provides exact limits for moisture, sodium, particle size, sulphur, calcium sulphate dihydrate, fluoride and certain heavy metals. The most important point for manufacturers is that this is not framed as an open-ended or permanent specification. The Order says that the notified specifications will apply for commercial trials for three years from the date of publication in the Official Gazette. For businesses planning to manufacture or commercially test Phosphogypsum (Granular), the immediate requirement is to understand the technical values correctly, and check whether their material can consistently meet them. Phosphogypsum Granular Notification 2026 at a Glance Particular Details Issuing authority Ministry of Agriculture and Farmers Welfare Department Department of Agriculture and Farmers Welfare Document type Order Order number S.O. 5105(E) Date 17 September 2026 Legal basis Clause 20A of Fertiliser (Inorganic, Organic or Mixed) (Control) Order, 1985 Product covered Phosphogypsum (Granular) Purpose Commercial trials Trial period Three years from Gazette publication Covered activity Manufacturing of Phosphogypsum (Granular) for commercial trials Main requirements Chemical composition, moisture, particle size, fluoride and heavy metal limits Application procedure Not expressly specified in this Order Fees Not expressly specified Testing frequency Not expressly specified Position after three years Not expressly specified The Order is short, but the technical specifications are precise. That means manufacturers cannot rely on a broad product description alone. The actual composition and physical properties of the material matter. What Is Phosphogypsum (Granular)? Phosphogypsum is a gypsum-based material associated with the production of phosphoric acid. The present notification, however, is not about Phosphogypsum in every form. It specifically deals with Phosphogypsum (Granular). That distinction matters because the notification does not only prescribe chemical limits. It also sets a physical particle-size requirement. In other words, the material must meet both its composition criteria and the notified granule-size condition. For a manufacturer, this means the product cannot be assessed only on the basis of sulphur or calcium sulphate content. Moisture, sodium, fluoride, heavy metals and particle size also need attention. What Has Changed Under the 2026 Notification? The Government has formally notified a technical specification for Phosphogypsum (Granular) when it is manufactured for commercial trials. The Order does not create a long application procedure in its own text. Instead, it tells manufacturers what the product must look like from a technical point of view. The notified areas include: moisture, sodium content, particle size, sulphur, calcium sulphate dihydrate, fluoride, and six heavy metal or contaminant limits. This gives manufacturers a clear technical benchmark for commercial-trial material. At the same time, businesses should avoid describing this Order as a permanent product approval. The three-year commercial-trial wording is central to the notification. Regulatory Framework Under the Fertiliser Control Order, 1985 S.O. 5105(E) has been issued under clause 20A of the Fertiliser (Inorganic, Organic or Mixed) (Control) Order, 1985. For this notification, the legal function is straightforward: the Government has prescribed specifications for Phosphogypsum (Granular) for a limited commercial-trial period. This Order should not be read as a complete replacement for the wider Fertiliser Control Order framework. A manufacturer may still need to examine other requirements that apply to its unit, manufacturing activity, sale, distribution, quality control or other regulated functions under the wider law. The safer compliance approach is to separate the two questions: What does S.O. 5105(E) tell the manufacturer? It tells the manufacturer what technical specifications the Phosphogypsum (Granular) should meet for the notified commercial trials. What may need to be checked separately? Any wider FCO requirement relating to manufacturing, licensing, authorisation, sale, testing, inspection or other compliance matters should be checked independently. This distinction helps avoid a common compliance mistake: assuming that one short product notification contains the full regulatory route. Scope and Applicability of the Phosphogypsum Granular Order The notification is product-specific and activity-specific. Category Covered Position Phosphogypsum (Granular) Covered Manufacturing for commercial trial Covered Manufacturing unit producing the notified product Covered Other gypsum products Not expressly covered by this Order Other fertiliser products Not covered by this product-specific notification Permanent manufacture after the trial period Not expressly dealt with Separate licence or approval requirements Need to be checked under the wider applicable framework The Gazette states that the notified specifications apply to Phosphogypsum (Granular) “to be manufactured by any manufacturing unit” for conducting commercial trials. The expression “any manufacturing unit” should not be interpreted as a blanket exemption from other legal requirements. It indicates that the notified specification is not restricted to one named unit. Who Can Manufacture Phosphogypsum (Granular) Under This Order? The wording of the notification is broad enough to refer to any manufacturing unit producing the product for the commercial trials covered by the Order. However, the notification does not say that a manufacturing unit can ignore other applicable FCO requirements. A business should therefore look at this Order as the technical specification document, not as an automatic licence or general manufacturing permission. Before starting commercial activity, manufacturers should check two things separately: whether the proposed product meets S.O. 5105(E), and whether the unit has met any other regulatory requirements applicable to its activity. This is where a fertiliser compliance consultant or specialised fertiliser compliance services can be useful, particularly where a business is unsure whether the notification alone is sufficient for its proposed activity. Three-Year Commercial Trial Period: What Manufacturers Need to Know The commercial-trial period is one of the clearest features of the notification. Item Position Trial period Three years Starting point Date of publication in Official Gazette Order date 17 September 2026 Permanent continuation Not expressly specified Renewal procedure Not expressly specified Extension Not stated in this Order The Order uses the date of publication in the Official Gazette as the starting point for the three-year period. Manufacturers should therefore be careful when preparing internal timelines. The Order date, Gazette publication date and the date on which a business actually starts production are not automatically the same thing. The commercial planning team should record the official Gazette publication details properly so that the trial window can be tracked accurately. What Does “Commercial Trial” Mean Here? The notification clearly uses the phrase commercial trials, but it does not explain every operational step connected with such trials. What the Order tells us is limited but clear. The Order specifies: the product, the commercial-trial nature, the duration, the physical and chemical specifications, the heavy-metal limits. The Order does not expressly specify: a separate application form, how to apply for the trial, a trial quantity, a prescribed laboratory, how often the material should be tested, a reporting format, inspection frequency, trial-monitoring procedure, or what happens automatically after the trial period. Businesses should therefore avoid creating an application or testing process merely from assumption. Where an operational question is not answered by S.O. 5105(E), the wider Fertiliser Control Order and later government directions should be checked separately. Complete Phosphogypsum Granular Specifications 2026 The Gazette sets six main technical conditions before dealing separately with heavy metals. Parameter Requirement Type of Limit Moisture Maximum 15.0% by weight Maximum Sodium as Na Maximum 0.75% by weight on dry basis Maximum Particle size At least 90% must pass 4 mm IS sieve and remain on 1 mm IS sieve Physical specification Sulphur as S Minimum 13.0% by weight Minimum Calcium sulphate dihydrate Minimum 70.0% on dry basis Minimum Fluoride as F Maximum 1.0% by weight Minimum Moisture: Maximum 15% The moisture content must not exceed 15.0% by weight. From a manufacturing point of view, moisture control can affect product handling and consistency. If the finished material crosses the notified ceiling, it will not match the specification given in the Order. Manufacturers may therefore need to monitor how the material is processed, stored and handled before evaluation. Sodium Content: Maximum 0.75% Sodium, expressed as Na, is limited to 0.75% by weight on a dry basis. The phrase “on dry basis” should not be dropped while reproducing this value in specification sheets or internal documents. It forms part of the technical requirement. Sulphur: Minimum 13% Sulphur, expressed as S, must be at least 13.0% by weight. Unlike moisture and sodium, sulphur has a minimum requirement. A lower value would fall outside the notified specification. This makes sulphur one of the composition parameters that manufacturers need to maintain consistently from batch to batch. Calcium Sulphate Dihydrate: Minimum 70% The product must contain at least 70.0% calcium sulphate dihydrate on a dry basis. For quality-control teams, this is another floor rather than a ceiling. The manufacturing process should therefore be capable of maintaining the required composition without allowing the figure to drop below the notified value. Fluoride: Maximum 1% Fluoride, expressed as F, is limited to 1.0% by weight. This is an upper limit. Manufacturers should keep this parameter separate from sulphur and calcium sulphate dihydrate because the compliance direction is different: sulphur, and calcium sulphate must meet minimum values, while fluoride must remain below its maximum. Particle Size Requirement for Phosphogypsum (Granular) Particle size is one of the more practical parts of the notification. The Order requires that not less than 90% of the material should pass through a 4 mm IS sieve and be retained on a 1 mm IS sieve. Put simply, most of the product should fall within the specified granular range. What this means practically At least 90% of the material must: pass through the larger 4 mm sieve, and remain on the 1 mm sieve. This means the manufacturer needs reasonable control over the granulation process. If a large portion of the product is too fine or too coarse, the batch may not meet the notified particle-size specification. The Order does not give an additional tolerance beyond this wording, so businesses should not create one themselves. Heavy Metal Limits for Phosphogypsum Granular Heavy-metal control is another major part of S.O. 5105(E). Heavy Metal / Parameter Maximum Limit Lead as Pb 100.0 mg/kg Cadmium as Cd 5.0 mg/kg Chromium 50.0 mg/kg Nickel 50.0 mg/kg Arsenic as As₂O₃ 10.0 mg/kg Mercury as Hg 0.15 mg/kg The values are expressed as maximum concentrations in milligrams per kilogram. This is important because a product may satisfy its main composition requirement but still fall outside the notified specification if one of the heavy-metal values crosses its limit. Why Heavy Metal Control Matters for Manufacturers A manufacturer cannot assess compliance by checking sulphur or calcium sulphate content alone. The final material also needs to remain below every listed contaminant ceiling. This creates a practical need to watch the quality of incoming material and understand how the production process affects the final composition. Manufacturers may need to review: variability in raw materials, contamination during processing, batch consistency, storage and handling conditions, reliability of analytical results. These are sensible manufacturing controls. They should not be confused with a statutory testing frequency, because S.O. 5105(E) does not prescribe how often these parameters must be tested. Maximum Limits and Minimum Requirements: The Difference The specification becomes much easier to understand when it is divided into three groups. Category Parameters Maximum limits Moisture, sodium, fluoride and heavy metals Minimum requirements Sulphur and calcium sulphate dihydrate Physical specification Particle-size requirement Maximum means “do not exceed” Moisture, sodium, fluoride and heavy metals need to stay at or below their notified values. Minimum means “do not fall below” Sulphur and calcium sulphate dihydrate need to remain at or above their notified levels. Particle size is different The sieve requirement looks at how much of the material falls within a particular size range. This simple distinction can help production and quality teams prepare more useful internal specification sheets. Quality Parameters Manufacturers Should Track For a manufacturing business, the Gazette can be converted into a simple internal quality checklist. Moisture: Check whether the material remains within the 15.0% ceiling. Sodium: Review sodium as Na on a dry basis. Granule Size: Check whether at least 90% of the product satisfies the notified sieve range. Sulphur: Confirm that sulphur is not below 13.0%. Calcium Sulphate Dihydrate: Confirm that the dry-basis value remains at or above 70.0%. Fluoride: Check that the value remains within the 1.0% maximum. Heavy Metals: Review every heavy metal separately rather than using a single combined result. A business using manufacturer compliance services or fertiliser regulatory compliance services can also map these values against its internal product specifications and identify where technical gaps exist before commercial production planning moves further. Is This a Permanent FCO Specification for Phosphogypsum Granular? The wording of S.O. 5105(E) does not support describing the present specification as permanent. The Order specifically says the specifications are being notified for conducting commercial trials for a period of three years. That means a website, technical note or sales presentation should avoid statements such as: “Phosphogypsum Granular has received permanent approval under FCO.” That goes beyond what this Order says. A more accurate statement is: “The Government has notified Phosphogypsum Granular specifications for three-year commercial trials.” The difference may seem small, but from a compliance point of view it is important. What S.O. 5105(E) Does Not Tell Manufacturers The notification contains the technical specification, but it does not answer every business question. Question Position in This Order Is there a separate application form? Not expressly specified What is the application fee? Not expressly specified Is there a fixed trial quantity? Not expressly specified How often must testing be done? Not expressly specified Which laboratory must be used? Not expressly specified What sampling method applies? Not expressly specified Is there a prescribed reporting format? Not expressly specified Is inspection mandatory under this Order? Not expressly specified Are packaging requirements given here? Not expressly specified Are labelling requirements given here? Not expressly specified Is a specific penalty stated? Not expressly specified Is there a renewal procedure? Not expressly specified Will permanent approval follow automatically? Not expressly specified This section is important for manufacturers because the absence of information from this Order should not be confused with an exemption from other applicable law. What Should Manufacturers Check Before Commercial Trials? Manufacturers do not need a complicated checklist to begin their internal review. They need a correct one. Step 1: Confirm the exact product Make sure the material being manufactured is genuinely covered by the description Phosphogypsum (Granular). Step 2: Prepare a specification comparison Compare the proposed product against each notified parameter. Step 3: Look for technical gaps A gap may exist where: moisture is too high, sodium is above the limit, sulphur is below the minimum, calcium sulphate dihydrate is below the minimum, fluoride is too high, particle size falls outside the required range, or a heavy metal exceeds its ceiling. Step 4: Review production consistency Passing one internal test does not necessarily mean every batch will have the same result. Businesses should understand where variation can occur. Step 5: Keep technical evidence Maintaining analytical reports, batch sheets and specification records can help the company track whether the material remains within the notified values. This is a practical internal recommendation. The Order itself does not prescribe a particular record format. Step 6: Check wider FCO compliance Do not stop with S.O. 5105(E). The manufacturing unit should separately review any wider legal requirement applicable to its activity. Step 7: Monitor later notifications Because the present specification is time-bound, businesses should monitor official updates during the commercial-trial period. Impact of the New Phosphogypsum Specifications on Manufacturers The notification may look like a small technical table, but for a manufacturer it can influence several day-to-day decisions. Production Planning The plant may need to maintain suitable process conditions so that composition and particle size stay within the required range. The production team therefore needs clear internal specifications, rather than depending only on the Gazette once production begins. Raw Material Control Variation in incoming material may affect: sulphur content, calcium sulphate content, fluoride, sodium, and heavy-metal levels. Manufacturers may therefore need better visibility over the quality of incoming material used in the process. Quality Control The notification gives exact numerical limits. Quality-control teams should therefore be able to compare results directly with those limits rather than using broad descriptions such as “acceptable” or “within normal range”. A useful internal report should clearly show: parameter, result, notified requirement, whether the result is above or below the relevant limit. Laboratory Coordination S.O. 5105(E) does not name a particular laboratory or prescribe a testing frequency. Still, reliable analytical data will matter for internal decision-making because the product specifications are numerical. A product testing compliance support provider may assist a business in understanding what parameters should be captured and how supporting technical records can be organised, subject to the applicable regulatory framework. Documentation and Record Keeping Even where this Order does not create a separate record format, businesses may find it useful to maintain: product specification sheets, test reports, batch records, raw material records, internal quality checks, copies of applicable notifications. Good documentation helps production, regulatory and quality teams work from the same information. Practical Challenges Businesses May Face Different manufacturing units may face different issues, but a few practical areas deserve attention. Keeping Granule Size Consistent The 1 mm to 4 mm sieve condition means the granulation process cannot be treated casually. Too much undersized or oversized material may affect conformity. Controlling Moisture During Storage A product may leave production with one moisture level and change during storage or handling. Businesses may therefore need to understand where moisture variation is occurring. Maintaining Minimum Sulphur and Calcium Sulphate Levels These are minimum requirements. A manufacturing process that produces wide batch-to-batch variation could make it harder to maintain the notified values consistently. Keeping Fluoride and Heavy Metals Below Their Limits These parameters work as maximum limits. Manufacturers may need to identify whether the source of variation is the incoming material, processing conditions or contamination at another stage. What Happens After the Three-Year Commercial Trial? The Gazette does not answer this question. S.O. 5105(E) does not say that the specifications will: automatically become permanent, automatically expire without any further action, automatically be extended, be converted into another product category, or result in permanent approval. A manufacturer should therefore avoid building a long-term regulatory assumption around the present notification alone. Future Government orders will need to be monitored. Regulatory Developments Manufacturers Should Monitor Businesses working with Phosphogypsum (Granular) may want to keep track of: changes to the present specifications, extension of the commercial-trial period, amendments to the Fertiliser Control Order, additional testing directions, additional reporting requirements, revised heavy-metal values, permanent product specification, if notified later, replacement or withdrawal of the commercial-trial notification. These are monitoring areas rather than new requirements created by S.O. 5105(E). Phosphogypsum Granular Manufacturer Compliance Checklist Check What to Review Status Product identification Is the material Phosphogypsum (Granular)? Review Moisture Maximum 15.0% Review Sodium Maximum 0.75% dry basis Review Particle size Minimum 90% within specified sieve range Review Sulphur Minimum 13.0% Review Calcium sulphate dihydrate Minimum 70.0% dry basis Review Fluoride Maximum 1.0% Review Lead Maximum 100.0 mg/kg Review Cadmium Maximum 5.0 mg/kg Review Chromium Maximum 50.0 mg/kg Review Nickel Maximum 50.0 mg/kg Review Arsenic Maximum 10.0 mg/kg Review Mercury Maximum 0.15 mg/kg Review Wider FCO requirements Check separately Review Future Government updates Monitor during trial period Ongoing This table can be used as an internal starting point, but it should not be presented as an official government form. What Businesses Should Do Now Manufacturers interested in this product should focus on a few immediate actions. First, review the notified specification line by line. Second, compare existing, or proposed product data with every parameter in S.O. 5105(E). Third, separate technical conformity from wider regulatory compliance. Meeting the product specification does not automatically answer every licensing, or manufacturing question. Fourth, keep proper technical records showing how the material has been assessed. Finally, monitor the Ministry of Agriculture and Farmers Welfare for any later order affecting the commercial-trial period or permanent regulatory position. How Corpseed Can Help with Fertiliser Compliance Services For manufacturers, the real difficulty usually begins after reading the notification. A business may know that sulphur must be at least 13% or that lead must remain below 100 mg/kg, but still have questions such as: Does this notification apply to our exact product? Are there other FCO requirements for our manufacturing unit? Which internal documents should be reviewed? Do our product specifications match the Gazette? What technical gaps should be corrected before moving ahead? Has any later notification changed the position? Corpseed can support businesses through relevant fertiliser compliance services, including: 1. FCO Applicability Review Corpseed can review the product, activity and regulatory position to help businesses understand which provisions may apply. 2. Technical Specification Review The notified limits can be mapped against the manufacturer's internal product specification to identify gaps. 3. Manufacturer Compliance Services Businesses can obtain support in reviewing the broader regulatory requirements connected with their manufacturing activity. 4. Product Compliance Services Technical parameters, product documents and regulatory references can be checked before the business proceeds further. 5. Regulatory Compliance Assessment Corpseed can help identify which requirements arise from S.O. 5105(E) and which need to be checked separately under the wider FCO framework. 6. Technical Document Review Specification sheets, available test reports and related compliance documents can be checked for consistency with the notified values. 7. Product Testing Compliance Support Where testing is relevant, Corpseed can assist with coordination and documentation support based on the applicable regulatory requirement. 8. Ongoing Regulatory Monitoring Because the present notification is linked to a three-year commercial-trial period, future orders may change the position. Businesses can use ongoing fertiliser regulatory compliance services to keep track of those changes. Corpseed does not replace the regulator or guarantee approval. The role of professional compliance support is to help manufacturers understand the applicable requirement, prepare the right documents and avoid proceeding on an incorrect interpretation of the notification. Key Takeaways The Phosphogypsum Granular specifications 2026, have been notified through S.O. 5105(E), dated 17 September 2026, by the Department of Agriculture and Farmers Welfare. The Order is specifically linked to commercial trials for three years from Gazette publication. The product must meet notified limits for moisture, sodium, sulphur, calcium sulphate dihydrate, fluoride and particle size. Separate maximum limits apply to lead, cadmium, chromium, nickel, arsenic and mercury. Manufacturers should not treat this Order as a permanent specification or a complete manufacturing approval process. The safest approach is to assess the product technically, review wider FCO obligations separately and continue monitoring official notifications during the commercial-trial period.